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Full text of "Restart of the Pilgrim I Nuclear Powerplant : hearing before the Committee on Labor and Human Resources, United States Senate, One Hundredth Congress, second session ... January 7, 1988--Plymouth, MA"

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S. R-RG. 100-598 

RESTART OF THE PILGRIM I 
NUCLEAR POWERPLANT 



HEARING 

BEFORE THE 

COMMITTEE ON 

LABOR AND HUMAN RESOURCES 

UNITED STATES SENATE 

ONE HUNDREDTH CONGRESS 
SECOND SESSION 

ON 

EXAMINING THE PROPOSED RESTART OF THE PLYMOUTH, MA, NUCLE- 
AR POWERPLANT, AND THE POTENTIAL IMPLICATIONS FOR THE 
PUBLIC HEALTH AND SAFETY IN THE SURROUNDING COMMUNITIES 



JANUARY 7, 1988— PLYMOUTH, MA 




Printed for the use of the Committee on Labor and Human Resources 



S. Hrg. 100-598 

RESTART OF THE PILGRIM I 
' NUCLEAR POWERPLANT 



HEARING 

BEFORE THE 

COMMITTEE ON 

LABOK AND HUMAN EESOUKCES 

UNITED STATES SENATE 

ONE HUNDREDTH CONGRESS 

SECOND SESSION 

ON 

EXAMINING THE PROPOSED RESTART OF THE PLYMOUTH, MA, NUCLE- 
AR POWERPLANT, AND THE POTENTIAL IMPLICATIONS FOR THE 
PUBLIC HEALTH AND SAFETY IN THE SURROUNDING COMMUNITIES 



JANUARY 7, 1988— PLYMOUTH, MA 




Printed for the use of the Committee on Labor and Human Resources 



U.S. GOVERNMENT PRINTING OFFICE 
83-478 WASHINGTON : 1988 

For sale by the Superintendent of Documents, Congressional Sales Office 
U.S. Government Printing Office, Washington, DC 20402 






COMMITTEE ON LABOR AND HUMAN RESOURCES 

EDWARD M. KENNEDY, Massachusetts, Chairman 

CLAIBORNE PELL, Rhode Island ORRIN G. HATCH, Utah 

HOWARD M. METZENBAUM, Ohio ROBERT T. STAFFORD, Vermont 

SPARK M. MATSUNAGA, Hawaii DAN QUAYLE, Indiana 

CHRISTOPHER J. DODD, Connecticut STROM THURMOND, South Carolina 

PAUL SIMON, Illinois LOWELL P. WEICKER, Jr., Connecticut 

TOM HARKIN, Iowa THAD COCHRAN, Mississippi 

BROCK ADAMS, Washington GORDON J. HUMPHREY, New Hampshire 
BARBARA A. MIKULSKI, Maryland 

Thomas M. Roluns, Staff Director and Chief Counsel 
Kevin S. McGuiness, Minority Staff Director and Chief Counsel 

(n) 



CONTENTS 



STATEMENTS 
Thursday, January 7, 1988, Plymouth, MA 

Page 

Agnes, Peter, Assistant Secretary of Public Safety; Sharon Pollard, Secretary 

of State of Energy; and Deborah Prothrow-Stith, Health Commissioner 434 

Prepared statements of: 

Mr. Agnes 437 

Dr. Prothrow-Stith 447 

Alexander, Lawrence, State Representative; Peter Forman, State Representa- 
tive; David Malaguti, chairman of the Pljmiouth Board of Selectmen; and 

Rachel Shimshak, Massachusetts Public Interest Research Group 97 

Prepared statements of: 

Mr. Alexander 100 

Mr. Forman 10*7 

Ms. Shimshak 123 

Bosen, Theodore, Anti-Nuclear Board member, prepared statement 861 

Boston Edison Co., prepared statement 780 

Cobb, Dr. Sidney, prepared statement (with attachments) 827 

Golden, William, State Senator, Norfolk, Plymouth District; Grace Healy, 
chairperson of Plymouth Committee on Nuclear Matters; Mary Ott, co- 
chairperson of Citizens Urging Responsible Energy; Neil Johnson, chairper- 
son of the Duxbury Citizens Committee on Nuclear Matters; Ann Waitkus- 
Amold, chairperson of the Disabled Persons Advisory Group on Nuclear 
Evacuation for the State Office on Handicap Affairs, and William Abbott, 

president of the Plymouth County Nuclear Information Committee, Inc 3 

Prepared statements of: 

Mr. Golden 4 

Mr. Abbott 16 

Ms. Waitkus-Arnold 25 

Mr. Johnson 33 

Ms. Ott (with attachments) 40 

Dr. Healy (with attachments) 55 

Kerry, Hon. John F., prepared statement (with an attachment) 458 

Kirby, Hon. Edward P., State Senator, Second Plymouth District, Common- 
wealth of Massachusetts, prepared statement 855 

Krimm, Richard, Assistant Associate Director of FEMA; Dr. Thomas Murley, 
Director of the NCR's Office of Nuclear Reactor Regulations; William Rus- 
sell, NCR's Regional Administrator, Region I; and Jack Doland, FEMA 

Region 1 531 

Prepared statements of: 

Mr. Krimm (with an attachment) 533 

Mr. Murley 600 

Kugelmann, Eileen, director, Mass Safe Energy Alliance (SEA): Cape Cod, 

prepared statement 853 

Murphy, Lt. Gov. Eveljm 322 

Prepared statement 325 

Shannon, Attorney General James 332 

Prepared statement 335 

Studds, Hon. Gerry E., prepared statement 456 

Theriault, Judy, prepared statement 854 

(HI) 



Articles, publications, etc.: 

The Pilgrim Generating Facility at Plymouth, Report of the Joint Special 
Committee established for the purpose of making an investigation and Page 
study, excerpts from, July 1987 128 

MASSPRIG— Blueprint for Chaos II: Pilgrim Disaster Plans Still a Disas- 
ter 162 

No Exit— The MASSPIRG Survey of Pilgrim Evacuation Planning, Sep- 
tember 1987 244 

Nuclear Lemon — Rateplayer Savings from Retiring the Pilgrim Nuclear 
Powerplant, November 1987 281 

Petition of Michael S. Dukakis, Governor and James S. Shannon, Attor- 
ney General for the institution of proceeding pursuant to 10 C.F.R. Sec. 
2.202 to modify, suspend, or revoke the operating license held by the 
Boston Edison Co. for the Pilgrim Nuclear Station, dated: October 15, 
1987 341 

Review of the status of the Mark I BWR Liner Melt-Through Issue, by 
G.A. Greene, Brookhaven National Laboratory Experimental Modeling 
Group, Upton, NY 552 

The Potential Adverse Health Effects of the Plymouth Nuclear Power 

Facility, by Belton Burrows, M.D., and Donald Muirheadm, Jr., M.D 846 

Communications to: 

Wyngaarden, Dr. James B., Director, National Institutes of Hegdth, from 
Senator Edward M. Kennedy, January 7, 1987 92 

Kennedy, Hon. Edward M., U.S. Senate, from James B. Wyngaarden, 
M.D., Director, National Institutes of Health, January 28, 1987 94 

Zech, Hon. Lando, Chedrman, Nuclear Regulatory Commission, from 
David P. Malaguiti, chairman, Board of Selectmen, September 2, 1987 ... 116 

Hurley, Thomas S., Director, Office of Nuclear Reactor Regulation, Wash- 
ington, DC, from David F. Malaguti, chairman. Board of Selectmen, 

November 6, 1987 118 

Questions and answers: 

Response of Mr. Krimm to questions submitted by Senator Kennedy 777 

Response of Mr. Murley to questions submitted by Senator Kennedy 617 



RESTART OF THE PILGRIM I NUCLEAR POWER- 
PLANT 



THURSDAY, JANUARY 7, 1988 

U.S. Senate, 
Committee on Labor and Human Resources, 

Plymouth, MA. 

The committee met at 7 p.m., at the Carver Regional High 
School, Plymouth, MA, Senator Edward M. Kennedy (chairman of 
the committee) presiding. 

OPENING STATEMENT OF SENATOR KENNEDY 

The Chairman. We'll come to order. We have a very full pro- 
gram this evening and this is an extremely important hearing. 
We're going to insist on order. We very much appreciate all the 
courtesies that have been provided by the townspeople here in 
Plymouth. We want to thank Mr. Simon, the superintendent of 
schools, for making the facility possible. 

As I mentioned, we have a full agenda, a number of panels. We 
want to make sure that the views of all of our witnesses are given 
adequate consideration, so we're going to insist that the hearing 
move along. In a situation like this, we are always caught in a 
time-bind between giving people an opportunity to speak and re- 
ducing the amount of time that people have, but that is the nature 
of many of these hearings, particularly those hearings that we 
have out in the field. 

We will ask all of the witnesses on the panels to limit their state- 
ments to three minutes. If they have additional comments, they 
can make those statements a part of the record. 

I would expect in a hearing like this that anyone who is going to 
appear before this committee ought to be able to summarize their 
views since we are looking at expert testimony. 

We will try and conclude this hearing around 9:30 or quarter of 
10. If it looks like we're going later then that, we'll take a brief 
break part way into the hearing, in a couple of hours. 

I'll make a brief opening statement, and then we'll move on to 
the first panel of witnesses. 

We're going to insist that all of our witnesses be sworn in during 
the course of these hearings. We are going to insist on order and 
we're going to desist from any exclamations of approval or disap- 
proval. We're going to maintain the decorum of a committee of the 
United States Senate. 

The Committee on Labor and Human Resources is here to look 
into the proposed restart of the Plymouth Nuclear Power Plant, 

(1) 



and its potential implications for the public health and safety in 
the surrounding communities. This committee has had a long in- 
volvement in oversight of nuclear powerplant safety and its effects 
on public health. In 1979, the committee held hearings on the acci- 
dent at Three Mile Island, and a year ago, we investigated the acci- 
dent at Chernobyl in the Soviet Union. 

Since the dawn of nuclear power, we have learned a great deal 
about its potential — and about its awesome possibilities for destruc- 
tion. We know more today about the health effects of radiation ex- 
posure, but many unanswered questions remain. And there is one 
fact of which we are certain, radiation if unleashed can cause un- 
paralleled injury and devastation. The world learned that lesson 
again from the tragedy at Chernobyl where 31 people lost their 
lives and thousands more will die of leukemia and other radiation 
related diseases. 

We know that nuclear plant accidents not only can happen, but 
do happen. In fact, the Nuclear Regulatory Commission estimates 
that in the next 20 years, there is a substantial chance for a core 
meltdown in a U.S. powerplant. 

In view of these serious implications, the NRC should be evaluat- 
ing more effective ways to improve public safety. Regrettably, the 
opposite has been true. In recent years, the Commission has weak- 
ened its efforts to protect the public. And the experience of Plym- 
outh is a case in point. 

Plymouth's history is replete with cases of mismanagement, 
equipment failure and regulatory violations. In May 1986, NRC of- 
ficials identified it as one of the least safe plants in the country. It 
has been involved in a number of enforcement actions, and in Jan- 
uary 1982, it was subjected to one of the largest NRC tines in histo- 
ry, totaling $550,000. 

Plymouth has also received excessive "minimum satisfactory" 
ratings by the NRC in its periodic assessment reports. The plant 
relies on a containment structure that many experts agree is likely 
to rupture in the event of high pressure buildup. 

Finally, and perhaps more important, both the Commonwealth of 
Massachusetts and the Federal Emergency Management Agency 
have concluded that residents living near the plant do not have an 
adequate evacuation plan in the event of a radiation emergency. 
Yet despite these serious ongoing problems, the Commission is con- 
tinuing with the process for restarting the plant. 

Residents and State officials have repeatedly called on the 
Agency for meaningful participation in the restart decisions. Their 
petitions have fallen on deaf ears. The NRC has consistently reject- 
ed requests to hold a hearing. To some extent this hearing is in- 
tended to fill that gap. 

Our concerns are not limited to people residing within the 10 
mile emergency planning zone, but for residents of Cape Cod and 
in the South Shore area as a whole. Residents fear that they will 
not be safely evacuated in the case of a nuclear accident, and their 
fear is compounded because the plant's record is unsatisfactory. 

Through this hearing, the committee will obtain a better under- 
standing of how the Commission makes its restart decision and 
how it evaluates recommendations for the public, from the State 
and from FEMA. I look forward to hearing from the witnesses. 



Our first panel of witnesses this evening is comprised of resi- 
dents of this area, Plymouth and Duxbury, which could be most di- 
rectly affected by a restart of the Pilgrim plant. They have done a 
tremendous amount of work on the subject, and they are the most 
vivid proof of the democratic process in action. So I welcome them 
here tonight. I would like them to come to the witness table and 
we'll all hear their presentations. 

They will be introduced to us by State Senator William Golden, 
who will also be testifying before us later this evening. 

STATEMENTS OF WILLIAM GOLDEN, STATE SENATOR, NORFOLK, 
PLYMOUTH DISTRICT; GRACE HEALY, CHAIRPERSON OF PLYM- 
OUTH COMMITTEE ON NUCLEAR MATTERS; MARY OTT, CO- 
CHAIRPERSON OF CITIZENS URGING RESPONSIBLE ENERGY; 
NEIL JOHNSON, CHAIRPERSON OF THE DUXBURY CITIZENS 
COMMITTEE ON NUCLEAR MATTERS; ANN WAITKUS-ARNOLD, 
CHAIRPERSON OF THE DISABLED PERSONS ADVISORY GROUP 
ON NUCLEAR EVACUATION FOR THE STATE OFFICE ON HANDI- 
CAP AFFAIRS, AND WILLIAM ABBOTT, PRESIDENT OF THE 
PLYMOUTH COUNTY NUCLEAR INFORMATION COMMITTEE, 
INC. 

Mr. Golden. Good evening, Mr. Chairman. For the record, my 
name is State Senator William Golden from the Norfolk, Plymouth 
District. 

It is my pleasure tonight to welcome you and to thank you for 
beginning tonight a process which the Nuclear Regulatory Commis- 
sion of the United States has denied the people of America and the 
citizens of America's hometown, Plymouth, and that is the opportu- 
nity to participate in the process of determining the future of the 
nuclear power plant here in Plymouth. 

The witnesses on this panel before you this evening, Mr. Chair- 
man, will be Grace Healy, the chairperson of Plymouth Committee 
on Nuclear Matters; Mary Ott, cochairperson of Citizens Urging 
Responsible Energy; Neil Johnson, chairperson of the Duxbury 
Citizens Committee on Nuclear Matters; Ann Waitkus-Arnold, 
chairperson of the Disabled Persons Advisory Group on Nuclear 
Evacuations for the State Office on Handicap Affairs, and William 
Abbott, president of the Plymouth County Nuclear Information 
Committee, Inc. 

[The prepared statement of Mr. Golden follows:] 



TESTIMGtJY OF MASSACHUSETTS STATE SENATOR WILLIAM B. GOLDEN 
BEFORE THE SENATE COMMITTEE ON LABOR AND HUMAN RESOURCES, 
JANUARY 6, 1988 . 

Mr. Chairman, 

I want to thank you and the members of this committee for 
the opportunity to testify before you this evening. I believe 
that the Piglrim Nuclear Power Station should be closed for 
reasons of safety, reliability and economics. There is 
overwhelming evidence that it is one of the worst-managed 
nuclear plants in the country. Its containment vessel has been 
proven to be defective. No emergency plans exist to adequately 
protect the public in the event of a serious accident at the 
plant. Evidence also has been mounting of serious security and 
radiological control problems at the plant and a recent study 
has demonstrated that it would be less expensive to shut the 
plant down than to allow it start up again. 

Yet, no level of government has acted decisively to shut 
this plant down. Under the Atomic Energy Act, states have 



almost no power regarding the safety of nuclear power plants. 
Federal authority - which is embodied in the Nuclear Regulatory 
Commission - has a virtual monopoly regarding the operation of 
nuclear plants. Unfortunately, the Nuclear Regulatory 
Commission has failed to distinguish between plants that are 
safe and those that are not. Rather than providing a fair and 
open forum for resolution o"f nuclear safety concerns, as well 



Page 2 

TESTIMONY 

as a mechanism for closing unsafe plants, the NRC has chosen to 
be an advocate for the nuclear industry. Despite all of the 
well-documented problems at Pilgrim, the NRC has chosen to keep 
the plant licensed. 

In July of 1986 I filed a petition with the NRC 
requesting a formal hearing on the suspension or revocation of 
Pilgrim's license to operate. Both the governor and the 
attorney general have since filed similar show-cause petitions 
with the NRC requesting hearings on the Pilgrim license. The 
NRC's failure to consider fully and fairly these petitions has 
convinced us that we cannot rely on the NRC to protect the 
public from the dangers presented by the Pilgrim nuclear power 
plant . 

We urgently and respectfully request that you join our 
efforts by using the power of this committee to demand that the 
NRC hold formal hearings so that Boston Edison may demonstrate 
why It should be allowed to operate a plant that is unsafe, 
unrealiable and uneconomical. 

A year and a half ago, I testified at length before the 
Congressional Sub-Committee on Energy, Conservation and Power 
in Washington, D.C., on the problems at Pilgrim. 
Unfortunately, very little has changed since that hearing, and 
the problems that I discussed in that testimony have not been 
resolved. Accordingly, I would like to submit that testimony 
again to your committee. A copy of it is attached. 



/ 



6 

T«.8timonv of Maaaachuaetta St ate Senator Willlaa fl. Golden befoyi* 
the Conaresaional Sub-Comait tee on Energy. Conaervatlon and 
Power. July 16. 1986, 

Mr. Chairauin: 

I vajit to thank you ajid the membera of the conunlttee for 
giving me the opportunity to appear before you today. Shortly 
alter World Nar II. the federal government Initiated a bold 
national policy to develop the peaceful use of nuclear energy. 
Today, many aspects of this policy have failed. These failures 
imperil the health, safety and welfare of milliona of Americana 
and steund in the way ot the development of a safe amd secure 
energy luture. it 13 critical that we appreciate what these 
policy failures have meant. 

The nuclear industry has not achieved uniform standards of 
excellence. :iome plants have state-of-the-art technology. Some 
are well -managed. Some are appropriately located in areas away 
from population centers. Some are etficient, coat-effective 
producers of electricity. A few — those run by the military- -have 
adequate security. 

However, many others were poorly designed and now have 
outdated equipment. They are located in areas that are densely 
populated or are vulnerable because of their geography. Some 
plants are poorly managed. Some no longer make economic sense. 
Nearly all civiliam reactors have inadequate protection from new 
and more sophisticated security threats. 

The federal government, which has the central responsibility 



lor nuclear safety, has tailed to understand local conditions and 
concerns. It has not made suilicient distinction between good 
and bad nuclear plants. 

Boston Edison s Pilgrim Nuclear Power Station--located in 
America' s home town, Plymouth, Massachusetts--ha3 come to 
symbolize the failure of this policy. The problems of this plant 
fall in five broad categories: management, technology, emergency 
planning, security and economics. 

Pilgrim has long suffered from poor management. In 1982, 
the Nuclear Regulatory Commission levied what was then the 
largest civil penalty in the agency's history against Boston 
Edison for management and safety problems. The NRC's SALP 
reports, or overall performance reviews, for 1981, 1982 and 1985 
gave Boston Edison the lowest possible rating for plcunt 
operations. The most recent ;5ALP report, issued this February, 
cited the company ror poor starting, supervision, procedures and 
self -assessment. A special NRC inspection report issued on April 
2, again pointed out stalling and organizational deficiencies. 
In May, the NRC commissioners told this committee that Pilgrim is 
one of the worst-run and least-safe plants in the country. In 
June, the Massachusetts Department of Public Utilities issued a 
sweeping criticism of Boston Edison' s overall management, 
concluding that the company had all but abdicated its 
responsibility for planning. 

These reports and disclosures have destroyed public 
confidence in Boston Edison s aUility to manage Pilgrim safely. 
They are sufficient cause for the NRC to hold public hearings on 



8 



whether this utility should be allowed to continue to run the 
plant. The NRC has refused to take this step, and because or 
this refusal, the public is rapidly losing confidence in the 
NRCs ability to regulate Pilgrim. 

1 urge this committee to use its influence to persuade the 
NRC to hold hearings on the possible suspension, revocation or 
transfer of Boston Edison s license to operate Pilgrim. 

The adequacy of Pilgrim s containment structure is another 
matter of serious concern. Pilgrim is a 19603 model General 
Electric boiling water reactor with a Marie 1 containment vessel. 
The NRCs chief safety official, Harold Denton, recently stated 
that there is a 90 percent probaiJillty of failure of a Mark I 
vessel in the event of a core meltdown. This level of risk is 
intolerable. The NRC should demand that Pilgrim's containment be 
upgraded to the highest standards the industry can provide. 

The NRC can no longer persist in ignoring important design 
distinctions among nuclear plants. It is time to determine 
whether it is more economical to upgrade the Mark I system or to 
close plants with Mark I containment permanently. 

No issue so plainly illustrates the failure ot national 
nuclear policy as emergency preparedness. ITie public might be 
more inclined to accept the pronouncements or the experts on the 
highly technical issues surrounding nuclear power if the 
emergency plans for nuclear plants were not so patently 
inadequate. 

The 10-mile emergency preparedness zone, which the NRC 
requires of all nuclear facilities, may make sense tor a plant 



located m the middle oi a western desert. But it is clearly 
inappropriate for densely populated urban and suburban areas of 
the Northeast. 

A serious accident at Pilgrim would have effects far beyond 
the 10-mile zone. Flans should be developed to deal with an 
emergency at Pilgrim that would affect Boston, which is 40 miles 
away, or Cape Cod, which is only 12 miles from the plant. 

Boston Edison, the NRC, and the Federal Emergency Management 
Agency have assigned a low priority to emergency planning. The 
Pilgrim plan has never received formal approval from FEMA or the 
NRC. FEMA did not even receive a copy of the most recent Pilgrim 
plan until ten months after it was prepared. 

Neither the utility nor the federal government has dealt 
with the cost or adequate emergency planning. In an actual 
emergency, the crucial links in tne chain or command are unpaid, 
minimally trained local civil defense directors. For any plan to 
work, professional civil defense departments with adequate staffs 
and equipment must be in place. 

In this age of global terrorism, political extremism and 
individual fanaticism, it is imperative that security be upgraded 
at Pilgrim and all other nuclear plants. Official NRC 
regulations call for strict security at nuclear plants. However, 
this official policy has not been effectively implemented by the 
nuclear industry or the NRC. 

In an attempt to lull the public into a comfortable feeling 
about nuclear power, the Atomic Industrial Forum- -a nuclear 
industry organization- -suggested last week that nuclear power 



10 



plants are ideal summer tourist attractions. ITiis attitude is 
irresponsible and dangerous. :3ecurlty interests require that the 
public be kept as rar away as possible from nuclear plants. 

The NRC has tailed to realize that the eif ectiveness of its 
elcLborate security regulations is no better than the individuals 
who carry them out. At Pilgrim this taslc falls to individuals 
who are recruited through classified ads in the local weekly 
newspaper stating, "We are looking for those individuals with a 
career as a nuclear security officer in mind and would like to 
earn $11,000 to $18,000. .. You must be at least 19 years old and 
must bring with you copies oi birth certificate, drivers license, 
high school diploma or G.E.D. certificate." Security at nuclear 
plants demands higher standards. 

At Pilgrim, security problems are compounded by reports or 
alcohol and drug abuse, horseplay m sensitive parts of the plant 
and continuing labor -management strife. 

This committee should seriously consider having the United 
;itates military or the Department of Defense police provide 
direct security for Pilgrim and all other nuclear plants. 
Nuclear facilities are not tourist attractions. They are 
sensitive installations which in the wrong hands could expose 
civillem populations to catastrophic dsmgers. 

Finally, national nuclear policy has failed because the 
federal government has lost sight of the policy's prime 
objective — cheap energy. A chairman of the Atomic Energy 
Commission once stated that nuclear power would give us 
electricity "too cheap to meter." This clearly has proven false. 



11 



Today, we need to re-examine ail of the old assumptions 
surrounding the economics ol nuclear power. 

A cost-benefit analysis of Pilgrim has not been conducted 
since the plant went on line 15 years ago. Pilgrim and other 
existing plants are becoming increasingly expensive to run, as 
the costs or maintenance and safety improvements escalate. The 
public IS demanding better security, management and safety at 
nuclear plants. These measures will cost money. The economics 
of all nuclear plants should be subjected to thorough reviews. 

These reviews also should talce into account items that are 
undervalued on company balance sheets or may not show up at all. 
The public has subsidized nuclear power by limiting utility 
liability for accidents through the Price Anderson Act. Civil 
defense planning and government regulation are other costs to the 
public of nuclear power. The future costs of decommissioning and 
waste disposal are still unlcnown. 

_I urge this committee to press for the suspension of 
Pilgrim 3 license until the following actions are tatcen; 

1) The NRC holds public hearings on whether Boston Edison is 
qualiiied to manage the plant. 

2) The reconstruction or replacement of the existing 
containment vessel so that Pilgrim has a state-of-the-art 
containment system. 

3) The creation of a 4u-mile emergency planning zone and the 
development of a new civil defense program, which would be funded 
by Boston Edison and would be capable of responding to a serious 
accident at Pilgrim. 



12 

4) Ttie lOfmatlOn of a military or Deiense Department police 
security iorce I'or Pilgrim and all other nuclear racilities . 

5) The compl etion ot an economic C03t/benetit analysis ot 
Pilgrim . 

Three Mile island and Chernobyl have changed forever the way 
Americans think about nuclear power. The test of our national 
nuclear energy policy no longer lies in a comlortable consensus 
between the utility industry and the NRC. To survive, nuclear 
power must prove itself not just in the nation' s capital but in 
Plymouth, Massachusetts, and other home towns throughout America. 
It is time for the rederal government to stop listening only to 
experts and technocrats and to start listening to the American 
people. No policy will succeed until public coniidence is 
restored in the technology and in the ability of governemnt to 
manage it in the public interest. 



13 

The Chairman. Well, thank you very much, Senator Golden. We 
will ask all of you if you would be kind enough to stand. 

[Witnesses sworn.] 

The Chairman. We'll start with Mr. Abbott. 

Mr. Abbott. Mr. Chairman, thank you for the opportunity to tes- 
tify before your committee. You have asked here tonight what will 
be the impact upon the health and safety of the communities sur- 
rounding the Pilgrim I plant should it be allowed to start up in the 
next few months. 

Others here tonight will address the issue of protection against a 
catastrophic accident and emergency planning. I would like to 
focus my brief comments and recommendations on the subject of 
radiation emissions for Pilgrim I and their control and their moni- 
toring, or as is usually the case, the lack thereof by the NRC. 

Over a year ago, I testified before two Massachusetts legislative 
committees advocating the funding of an effective monitoring 
system by the State of Massachusetts to do what the NRC does not 
perform. Legislation was introduced, but it died a few days ago in 
the final hours of the 1987 legislative session; thus we must still 
rely on the NRC to police the operations of Pilgrim I; a reliance, 
which based on past experience, certainly gives me and the resi- 
dents of this area little comfort. 

Pilgrim I has had a history of continued unplanned radiation re- 
leases, which are among the highest in the nation. Again and 
again, we see reports of radiation releases in the files; we must dili- 
gently dig through unpublicized NRC reports to see that there is 
this recurrent public health menace. 

Now, Senator, given the reports of substantially higher than av- 
erage incidents of cancer in Plymouth and towns downwind of the 
plant, the do-nothing approach by the State of Massachusetts and 
by the NRC can no longer be tolerated. To date, our efforts have 
been singularly unsuccessful in getting the NRC to do anything 
about this. They have failed miserably over the years, both in dis- 
charging their public protection function, and equally as impor- 
tant, in giving the public any comforting perception that it is ful- 
filling this function. 

Operating from a distance, whether it be King of Prussia, PA, or 
Washington, the NRC's typical involvement is to become activated 
after receiving a report from Edison; dispatch a team to the site; 
listen to Edison's explanation, and then generally endorse and 
ratify Edison's report with the usual conclusion, without any fur- 
ther investigation, that the public health was not, in fact, impacted 
by the incident. 

Massachusetts, likewise, has effectively failed to monitor the 
plant. We, through a Federal court suit years ago, got the Depart- 
ment of Public Health to install dosimeters in Plymouth and sur- 
rounding towns to monitor the release of radiation. 

Unfortunately, the carrying out of this function has been proven 
nearly worthless since the devices are only read quarterly; results 
are hidden from public view, and even worse, Mr. Chairman, no at- 
tempt is made to correlate the reading of these devices with known 
accidents at the plant which could lead to off-site releases, despite 
Edison's predictable, self-serving statements that all releases are 
contained within the site perimeter. 



14 

Let me illustrate this fundamental failure with one example to 
show you that the responsible authorities are not protecting the 
citizens of the South Shore. We researched this ourselves. 

In June 1982, Edison sent a detailed report to the NRC regional 
office explaining that highly radioactive resin beads and particu- 
late matter, which had accumulated over an extended period of 
time, were found to have been accidently injected into the ventila- 
tion system and from there to the outside of the building. This ma- 
terial was discovered on the roofs of several of the buildings and on 
the grounds of the Pilgrim I plant site. 

The Region I NRC office dispatched a team to the site and found 
that this material had been probably released through the vent 
duct which exhausts to the atmosphere at an elevation of about 100 
feet. Ten cubic feet of this highly radioactive resin was found in 
the standby gas treatment system inlet plenum. This is the source 
of releases of radioactive materials to the atmosphere. 

Now, despite the very serious potential of this accident for off- 
site contamination and the carrying away of radioactive dust by 
the winds, no effort was made to read the off-site TLDS — there are 
three separate sets of these maintained by the NRC, Boston Edison 
and the State of Massachusetts — no efforts were made to correlate 
those readings with this observed accident. Nobody bothered to 
read them to see if Edison's statement made at the time — that no 
radiation escaped off-site — was, in fact, true. 

Now, this failure was probably due to the fact that the readings 
did not become available — they are only read quarterly — until sev- 
eral weeks after the particular release. 

We did check the readings, and the results were highly signifi- 
cant. For instance, in the summer of 1982, all TLD locations as 
measured by Edison, the NRC and the State showed a large rise 
and then declined by the same percentage, indicating a consistent 
pattern. Likewise, the dose-rate decreased with distance away from 
the plant as one would expect from a point source. The zone closest 
to the plant showing the largest dose-rate. 

The Chairman. What do those kinds of increases mean in practi- 
cal terms, in terms of the health hazard for the population? 

Mr. Abbott. Senator, they are substantially in excess of back- 
ground radiation, and I think that anytime you add to the back- 
ground radiation more radiation from the Pilgrim nuclear plant, 
you are adding to the health hazard of the people of the area. 

We have asked the State of Massachusetts to hold hearings to set 
new levels of radiation standards, emission standards. This is one 
of the problems we have with the NRC, that the standards that 
they have are not consistent with current scientific evidence. But 
the key here is that although the statement was made that nothing 
escaped, clearly radiation did escape. Out as far as 20 miles toward 
the northwest, all locations showed an increase of radiation. The 
existing background dose-rates were nearly tripled in the third 
quarter of 1982. 

About a year ago, I discussed this at a meeting with NRC at a 
public forum. They told me that they had not read the — the gentle- 
man that was there was on the NRC team that inspected the plant 
after that accident — had not read the TLD data. He said some four 
years after the incident he thought the TLD data was "worth 



15 

checking." The State Department of Public Health did not do much 
better. 

The Chairman. I'll give you another minute. 

Mr. Abbott. The remedy to this failure is starkly obvious. Either 
the NRC or the State or both should gear up with the necessary 
manpower and equipment to monitor the day-to-day operations at 
Pilgrim I, including all planned and unplanned releases of radi- 
ation on a regular, continuous basis, not this haphazard hit-or-miss 
system that we have now. Monitoring equipment should be read on 
a real-time, continuous basis up to at least 20 miles from the plant, 
and the results made public so we don't have to search for them. 
Until that is in place. Senator, I say the plant should not be al- 
lowed to re-open. 

The people of the South Shore deserve to know what they are 
being exposed to. It is of fundamental importance to our mental 
well-being and physical health that this system be in place. We ask 
the support of your committee to insure that the NRC not give its 
approval to Pilgrim restart, unless and until an effective real-time, 
continuous radiation monitoring system has been fully implement- 
ed. Thank you. 

[The prepared statement of Mr. Abbott follows:] 



16 



statement of William S. Abbott 

President, Plymouth County Nuclear Information Committee, 

before Senate Committee on Labor and Human Resources, 

on January 7, 1988 

Thank you for the opportunity to testify before your Committee, 
You have asked here today what would be the impact upon the health 
and safety of the surrounding communities from the operation of 
Pilgrim I should it be allowed to start up by the NRC in the next 
few months. Others here today have addressed or will address the 
issues of protection against a catastrophic accident and emergency 
planning. I would like to focus my comments and recommendations 
on the subject of radiation emissions from Pilgrim I and their 
control and their monitoring (or as is more usually the case, the 
lack thereof) by the NRC. Over a year ago I testified before two 
separate Massachusetts legislative committees advocating the 
instituting and funding of an effective monitoring system by the 
State of Massachusetts to be sure the citizenry is protected from 
the operations of Pilgrim I. Legislation was introduced, but this 
week it died in the final hours of the 1987 legislative session. 
Thus, until such legislation is once again introduced and enacted, 
we must rely on the NRC to police the operations of Pilgrim I - a 
reliance which based upon past experience certainly gives me, 
and I presume many others, little comfort- 
Pilgrim I has had a history of continued unplanned 
radiation releases which are among the highest in the nation. 
Again and again we see reports (such as the 1986 SALP report) of 
unplanned radiation releases; only with diligent digging in the 
morass of NRC unpubliciSed reports do we see the true extent of 



17 



this recurrent publ ic health menace. Now, given the reports 
of substantially higher than avera<3e incidences of cancer in 
Plymouth and towns downwind of the plant, the do-nothing approach 
by the State of Massachusetts and by the NRC can no longer be 
tolerated. 

This history of Pilgrim I for the past 15 years has been 
one of citizen groups digging through the voluminous microfilm and 
technical reports, most usually in the Public Document Room in the 
Plymouth Public Library, to find the obscure reports of the releases 
of radiation by Pilgrim I into the Plymouth environs — and then 
trying to get the NRC and the State Department of Public Health 
to do something about it. To date our efforts have been singularly 
unsuccessful. The NRC has failed miserably over the years — both 
in discharging its public protection function, at least as regards 
Pilgrim I, and in giving the public any comforting perception that 
it is fulfilling this function. Operating from a distance, whether 
it be King of Prussia, Pennsylvania or Washington, D.C., the NRC's 
typical involvement is to become activated after receiving a report 
from Boston Edison, then to dispatch a team to the site, listen to 
Edison's explanation, and then generally endorse and ratify Edison's 
report — with the usual conclusion, without any further investigation, 
that the public health was not adversely impacted by the incident. 

The State of Massachusetts likewise has failed over the 
years to effectively monitor the plant's operations. And it is 
not for lack of trying on our part that the State is not performing 
this function. Several years ago as a result of federal court 
litigation involving Pilgrim I brought by Plymouth County 
Nuclear Infromation Committee, the State Department of Public 



18 



Health installed several thermoluminescent dosimeters ("TLD'S") in 
Plymouth and surrounding towns, supposedly to monitor the release 
of gamma radiation from Pilgrim I. Unfortunately, the carrying 
out of this function has proven to be nearly worthless since the 
devices are only read on a quarterly basis and the results are 
virtually hidden from public view — and even worse, no attempt is 
made to correlate the readings of these devices with known abnormal 
occurrences at the plant which could lead to offsite releases 
despite Edison's predictable self-serving statements that all 
radiation releases are contained within the site perimeter. 
Let me illustrate this fundamental failure of the 
responsible authorities to protect the citizens of the South Shore 
by a case in point which I researched myself. In June 1982, Edison 
sent a detailed report to the NRC Region I office explaining that 
highly radioactive resin beads and particulate matter, that had 
accumulated over an extended period of time, was found t'o have 
been accidently injected into the duct-work of the ventillation 
system, and from there to the outside of the building. This 
radioactive material was discovered on the roofs of several of the 
Pilgrim I buildings and on the ground. The NRC Region I office 
dispatched a team to the site which found that the resin had been 
probably released through the reactor building vent-duct which 
exhausts to the atmosphere at an elevation of approximately 100 
feet. Ten cubic feet of this highly radioactive resin was found 
in the Standby Gas Treatment System inlet plenum (the source of 
releases to the atmosphere). Despite the very serious nature 



19 



of this accident and the potential for oCEsite contamination and 
the carrying away of radioactive dust by the winds, no effort was 
made to read the off site TLD's (separate sets of TLD's are 
maintained by the NRC and Boston Edison, in addition to the TLD's 
maintained by the State), and correlate such readings with the 
observed accident at the plant. Neither the NRC nor the State 
ever bothered to read their TLD's to see if Edison's typically 
pollyannish statement that no radiation escapted off site was in 
fact true. This failure was no doubt partly due to the fact that 
^he TLD readings do not become available, given the current 
practice of reading them quarterly, until several weeks after any 
particular release. I did check the readings and the results are 
highly significant. For instance, in the summer of 1982, all TLD 
locations, as measured by Edison, the NRC, and the State, showed a 
large rise and then declined by about the same percentage, 
indicating a consistent pattern. Likewise, the dose-rate 
decreased with distance away from the plant, as one would expect 
from a point-source, the zone closest to the plant (0-0.16 miles) 
showing the largest dose-rate, thereby confirming that the accidental 
escape of highly radioactive wastes reported to the NRC did in 
fact lead to offsite contamination. At all locations as far away 
as 21 miles to the northwest, the existing background radiation 
dose-rates were nearly tripled in the third quarter of 1982. 
Despite the potential health effects of this release of radiation, 
a member of the NRC inspection team who had visited the plant 
after this release told me in the summer of 1986 that his team 
had not road the TLD data, and that then, some four years after 
the incident, he thought that these readings might be "worth 



20 



checking". And as for the State Department of Public Health, 
suffice it to say that it took me many long hours of digging 
and prodding to even get the State data out of the offices of 
the State employee who collected it -- just as with the NRC no 
attempt whatsoever had been made by the Department of Public 
Health to correlate this data with the accident. 

This incident and the lack of follow-up by the responsible 
monitoring authorities illustrates the failure of the system 
as it exists today to protect adequately the public health of 
the citizenry from the operation of Pilgrim I in what has become 
the fastest growing area of our State. The remedy for this failure 
is starkly obvious: Either the NRC or the State, or both should 
gear up, with the necessary manpower and equipment, to monitor 
the day-to-day operations of Pilgrim I, including all planned 
and unplanned releases of radiation off-site, on a regular continuous 
basis -- a complete system of radiation detection devices should 
be installed off-site at various distances from the Plant, and 
read constantly and continuously -- and the results made public. 
Such a system, if properly designed and implemented, could add 
measurably to the public's confidence that its safety and health 
were being duly considered and protected. 

And there is even more that the State can do -- the 
State of Massachusetts has the legal power to set its own level 
of maximum permissible airborne radioactive emissions from Pilgrim 
I. Under Section 122 of the Clean Air Act Amendments of 1977, 
Congress specifically provided that the States have the legal 
authority to set emission standards at levels which are more 



21 



stringent than standards imposed by the NRC or the EPA. And 
tho NRC itself has recognized that the setting of such standards 
by a State might even prevent the construction of nuclear plants 
or halt the operation of existing facilities. 

Meanwhile, the NRC continues to rely upon standards 
of permissible radiation releases which are obsolete and understate 
by many times the actual health risks posed by such emissions 
of radiation. Obviously these permissible radiation standards 
should be updated by the NRC, but having seen the way the NRC 
operates for the past 15 years, I have little hope that the NRC will 
do so. In the absence of NRC action it is imperative that 
the State of Massachusetts act in this critical area, to design 
and set standards of radiation releases which must be met by 
nuclear plants operating within the State -- standards that will 
take into account the latest of scientific evidence on the health 
effects of low-level radiation, and then to engineer and implement 
a monitoring system to ensure that Pilgrim I does not exceed 
such standards, and if it does, to shut it down. It is of fundamental 
importance to the mental wellbeing and physical health of the 
citizens of the South Shore that such a system be in place before 
the plant is allowed to restart. Ke ask the support of your 
Committee to ensure that the NRC not give its approval to Pilgrim 
restart unless and until an effective realtime continuous monitoring 
system, run either by the NRC or the State of Massachusetts (not 
Boston Edison) has been fully implemented. 



22 

The Chairman. I'm going to come back to some questions for Mr. 
Abbott. I would like to try and go down the panel first, and then 
come back with some questions. I'll ask that Ann Waitkus-Arnold 
testify next, and then we'll proceed to the others, she is the Chair- 
woman of the Plymouth Commission on the Handicapped. 

Ms. Waitkus-Arnold. Thank you, Senator. 

The Chairman. Put that mike a little closer. 

Ms. Waitkus-Arnold. Thank you for the opportunity to testify 
before your committee. My name is Ann Waitkus-Arnold and I rep- 
resent the Massachusetts Office on Handicap Affairs, and chair- 
woman for the Disabled Persons for the Disabled Advisory Group 
on Nuclear Evacuations. 

I'm also the chairperson for the Public Commission on Handicap 
Affairs, Resource Coordinator for We the People and 

The Chairman. Slow down just a little, Ann, so we can all 

Ms. Waitkus-Arnold. OK. I'm also a member of the Massachu- 
setts Advisory Council on Handicap Affairs. 

The purpose of the advisory group is to make recommendations 
to be used by the Massachusetts Civil Defense Agency and the util- 
ities. This is a crucial first step in a statewide effort to insure that 
all people are included in planning, not only for Pilgrim I, but for 
Massachusetts residents affected by Yankee Atomic and for 
Yankee Rowe nuclear power plants. 

In my official capacity for the State, I have had the opportunity 
to talk with representatives from Civil Defense, Department of 
Public Safety, Boston Edison, Yankee Atomic, and I've addressed 
FEMA and the NRC on several occasions. However, I have seen 
little evidence of any real efforts to insure the health and safety of 
the special needs of populations by these agencies. They may give 
the appearance of concern, but I have found this to be mostly lip- 
service. Government assurances to protect the public in the event 
of an accident at Pilgrim I have been deceptive and grossly irre- 
sponsible. 

The NRC has licensed nuclear facilities that have not included 
people with disabilities and pain. And only recently has FEMA con- 
cluded that plans for Pilgrim I plant are not adequate for people 
with special needs. 

The State's newest revised draft of October 1987, developed with 
the assistance of Boston Edison, now states that potassium iodine 
will be stockpiled for use for those who will be left behind, instead 
of including all citizens in actual evacuations 

The Chairman. Would you like to expand on that point? 

Ms. Waitkus-Arnold. OK. 

The Chairman. On the significance of storing that particular 
chemical. 

Ms. Waitkus-Arnold. They will be storing that chemical — the 
chemical protects the thyroid gland against radioactive iodine. The 
problem that we have with this is that it is only to be given out to 
people in nursing homes, hospitals and 

The Chairman. Let's get a little more complete picture. You are 
talking about there being included in an evacuation plan the sug- 
gestion that some people might leave, but might leave those who 
have physical disabilities behind? 

Ms. Waitkus-Arnold. Right. 



23 

The Chairman. People in nursing homes or who have other 
physical disabilities. They are going to be inoculated with this, or 
they take a pill. They take a pill, and they take whatever radiation 
there is. The other people have effectively left, and they leave the 
handicapped or physically disabled — or physically challenged, as 
my son would say — behind, to take their pills and hope for the 
best? 

Ms. Waitkus-Arnold. Right. This is a drug that can cause severe 
allergic reactions, hemorrhaging, and even death. 

Mr. Chairman. Do you have any instant reaction to that type of 
an evacuation plan? I can't let that quite slide by so quickly. 

Ms. Waitkus-Arnold. My instant reaction is anger, discrimina- 
tion, and I think it is a very inhuman way to treat people, especial- 
ly elders and disabled. Those are the only people targeted out for 
this particular type of treatment. 

The Chairman. The elderly and the disabled? 

Ms. Waitkus-Arnold. Elderly and disabled. That means that we 
have a discriminatory system in our country today. 

In my opinion and the opinion of the advisory group, Edison has 
spent a great deal of time lulling people into a false sense of securi- 
ty, and h£is consistently been misleading and deceptive on the 
issues of special needs. 

One example is a special needs survey done by Edison at the in- 
sistence of our disability group. The purpose of the survey was to 
identify people who will need assistance during evacuation; unfor- 
tunately, they ignored our suggestions and offers of assistance. The 
resulting survey was designed in such a way as to exclude most of 
the people with disabilities. 

Consequently, there is a stunning discrepancy between the 1986 
Disability Census figure, which shows 4,000 people in Plymouth 
alone with severe limitations and the utilities' figures showing only 
474. Edison then incorporated these erroneous figures into their 
new evacuation time estimates of special needs population. 

The Chairman. As I understand, partially because many of those 
who have physical disabilities don't report them; is that right? 

Ms. Waitkus-Arnold. No. It's because the survey was kind of a 
bogus survey. It wasn't sent out to people — it wasn't sent out to 
any handicapped or elderly house. They refused to send it out to 
every household in the town of Plymouth. It wasn't understandable 
by many disabled people; elders who had no idea that the service 
pertained to them because it spoke about severe disabilities, and it 
did not include a lot of questions about many disabilities. Obvious- 
ly, if one is blind, one would not be able to fill out the survey. 

In addition, we have advocated for 2 years that Edison comply 
with NRC's regulations to notify and alert all segment of the com- 
munity in case of an accident of Pilgrim I. This includes people 
who are deaf and hard of hearing. 

I have testified before the NEC several times on this issue; how- 
ever, proper action has not been taken to obtain and distribute spe- 
cial equipment to the 420 residents who have requested it from 
Boston Edison. I feel that the NRC is complicit in its violations of 
federal law because they have been aware of this violation, but 
have taken no action to make Boston Edison comply. 



24 

With few exceptions, there appears to be an attitude from the 
Federal Government on down that some elderly and disabled 
people are not worth consideration because exclusion is permitted. 
The quality of our Government is reflected by the way the Govern- 
ment deals with its citizens that are in need of assistance, and 
until this attitude changes, disabled people will be continued to be 
treated as second-class citizens. I'm talking about people who we 
love and care about, our children, parents, grandparents who may 
have hearing, vision or physical disabilities, the thousands of elder- 
ly who will need assistance in an evacuation; our disabled veterans 
in homes and hospitals and the many retarded persons in group 
homes, who may not even recognize that an emergency exists. 
What will happen to them during an emergency? 

We are not asking for special treatment, only equal treatment. 
Failure to include elderly and disabled in planning is deprivation 
under the equal treatment under the 4th and 14th amendments. 
We are not sajdng we ought to come first. We just want the same 
chance to escape as everyone else has. Basic civil rights are the 
birthright of all Americans and second class citizenship should no 
longer be allowed. Realistic and humane emergency plans must be 
developed for all people and every town and village from Cape Cod 
to the borders of New Hampshire affected by this plant. Unless a 
workable plan can be designed for everybody, and until such a plan 
can be tested and implemented. Pilgrim I should remain closed. 

There have been serious incidents which reveal the GE contain- 
ment systems, like the Pilgrim I containment, had an unsafe 
design, making it very unlikely to withstand a major accident. This 
report was kept secret by GE and the NRC for 12 years. In addi- 
tion, the report stated that radioactive and chemical waste in 
Pl5anouth by Boston Edison was duly reported to State and Federal 
authorities and has yet to be investigated after 7 years. We feel 
that waiting 7 years is 7 years too long to find out whether our soil 
and water have been contaminated. 

In light of the above examples, there must be an immediate mor- 
atorium on the operation of all nuclear plants which affect Massa- 
chusetts residents, and Congress must hold a full investigation into 
why the NRC has failed to protect the health and safety of elderly 
and disabled people as well as the rest of the general public. Thank 
you very much for inviting me to speak. 

The Chairman. We'll come back to you. Do you know of your 
own knowledge whether other evacuation plans treat the handi- 
capped like this? 

Ms. Waitkus-Arnold. Jerome Plant. 

The Chairman. Where they have similar kinds of 

Ms. Waitkus-Arnold. Exactly. 

[The prepared statement of Ms. Waitkus-Arnold follows:] 



^&* 



25 



The Disabled Persons' Advisory Group 
on 
Nuclear Evacuation 



Ann Waitkus-Arnold Post Office Box 3803 617-747-4574 

Chair Plymouth, MA 02361 Voice &TDD 



Honorable Edward M. Kennedy 
2400 J.F.K. Federal Building 
Boston^ Ma. 02108 

Mr Chairman; 

My name is Ann Waitkus-Arnold, and I represent the Massachusetts 

Office on Handicapped Affairs as the Chairwoman of the Disabled Persons' 
Advisory Group on Nuclear Evacuation. I am also the Chairperson of the 
Plymouth Commission on Handicapped Affairs, Special Needs Co-ordinator 
for We the People, Inc. of the United States, and a member of the Plymouth 
Nuclear Affairs Committee and the Massachusetts Advisory Council on 
Handicapped Affairs. The purpose of the Advisory Group is to make re- 
commendations to be utilized by the Massachusetts Civil Defense Agency 
and the Utilities. This is a crucial first step in a statewide effort 
to insure that ail people are included in planning, not only for Pilgrim 
I, but for Massachusetts residents affected by Yankee Atomic in Rowe, and 
the Vermont Yankee Nuclear Power Plant. In my official capacity for the 
State, I have had the opportunity to work with representatives from 
M.C.D.A., the Departmentof Public Safety, the Boston Edison Company, 
Yankee Atomic, and I have addressed the Federal Emergency Management Ag- 
ency and the Nuclear Regulatory Commission on several occassions. 

However, I have seen little evidence of any real efforts to insure 
the health and safety of the Special Needs Populations by these agencies. 
They may give the appearance of concern, but I have found this to be 
mostly Up service. Government assurances to protect the public in the 



26 



(2) 

event of an accident at Pilgrim I have been deceptive and grossly irr- 
esponsible. The NRC has licensed Nuclear facilities that have not in- 
cluded people with disabilities in Planning, and. only recently has 
FEMA concluded that plans for the Pilgrim I Plant are not adequate for 
people with Special Needs although I realize the NRC is not obliged 
to take advice from FEMA. The States newest revised Plan, of October. 
1987. developed with the assistance of Boston Edison, now states that 
Potassium Iodide will be stockpiled for use by those who will be left 
behind, instead of including all citizens in actual Evacuations. Who 
are these people who will be left behind? - People in Hospitals. Nurs- 
ing Homes and Detention Centers, including the Plymouth County Farm. 
This proposed use of a drug which can cause severe allergic reactions, 
hemmorrhaging. and even death, is inhumane and totally unacceptable. 

In my opinion, and in the opinion of the Advisory Group. BECo 
has spent a great deal of time and money lulling people into a false 
sense of security, and has been consistently misleading and deceptive 
on these issues. One example is the Special Needs Survey, done by BECo. 
at the insistance of the Disabiltiy Group. This group included people 
with disabilities, representatives from Independent Living Centers, 
and State Agencies. The purpose of that Survey was to identify people 
who will need assistance during Evacuation. Unfortunately, they refused 
our input andParticipation in developing a workable document. and. instead. 

the Survey was not done in good faith, and did not collect the needed 
information. Consequently, there was a stunning discrepancy between the 
1986 Disability Census Figures showing 4.000 people with severe limit- 
ations in Plymouth alone, and the Utilities' figures showing only ^7^. 
BECo then incorporated their erroneous figures into their new Evacuation 
Time Estimates for Special Needs Populations, thereby calling into 
question the validity of this document. 



27 



(3) 



In addition, we have been advocating for two years that BECo comply 
With NRC Regulation to "notify and Alert all segments of the community" 
in case of an accident at Pilgrim I. This includes people who are deaf 
and hard-of-hearing. I have testified before the NRC several times on 
this issue, however, proper action has not been taken to obtain and 
distribute special equipment to the 421 residents who have requested 
It from BECo. I feel the NRC is complicit in this violation of Federal 
Law because they have been made aware of this violation, but have taken 
no action to make BECo comply. 

With few exceptions, there appears to be an attitude from the Fed- 
eral Government on down that elderly and disabled people are not worth 
consideration, because exclusion is pisrmitted. This is defacto 
discrimination. The quality of our Government is reflected by the way 
the Government deals with it's citizens who are in need of assistance, 
and, until this discriminatory attitude changes, disabled people will 
continue to be treated as second class citizens. I'm talking about people 
whom we love and care about - our children, parents and grandparents 
who may have hearing, vision, or physical disabilities, the thousands 
of elderly who will need special assistance, our disabled veterans in 
homes and hospitals, and the many retarded persons in Group Homes, who 
may not even recognize that an emergency exists. What will happen to 
them during an Emergency? These people are human beings who are impor- 
tant to our communities. We are not asking for special treatment, only 
equal treatment. Failure to include elders and disabled citizens in Ev- 
acuation Planning is depravation of Equal Treatment under the Fifth and 
Fourteenth Amendments, we're not saying we want to be first - we just 
want the same chance to escape as everyone else, however small that 
may be. Basic Civil Rights are the birthright of all Americans, and 
second class citizenship must not be allowed. Realistic and humane 



28 



(4) 



Emergency Plans must be developed for all people in every town and 
village from Cape Cod to the borders of New Hampshire! Unless s work- 
able plan can be designed for everyone, and until such a plan can be 
tested and implemented. Pilgrim I must remain closed. 

There have been serious incidents, including the Reed Report, 
which revealed that GE containments, like the Pilgrim I vessel, 
have an unsafe design making it very unlikely to withstand a major 
accident. This report was kept secret by GE and the NRC for 12 years! 
In addition, the reported dumping of radioactive and chemical waste in 
Plymouth by BECo. duly reported to State and Federal Authorities, has 
yet to be investigated after seven years. We feel that waiting seven 
years is seven years too long to find out whether our soil and ground 
water have been contaminated. 

In light of the above examples, there must be an immediate 
Moratorium on the operation of all Nuclear Plants which affect Mass^ 
residents, and Congress must hold a Full Investigation into why the 
NRC has failed to protect the health and safety of Elderly and Disabled 
people, as well as the rest of the general public. 

Thank you. Mr. Chairman, for inviting me to speak on these issues, 
and 1 would be happy to answer any questions you might have. 

Ann Waitkus-Arnold 
Chairwoman 



29 




^/le J^dX/u/'/on ^/ace 3^om /SOS 

^oi/o/i 0^06' 



MICHAEL S. DUKAKIS 
Governor 

727-7440 
JIM GLEICH Vccc i TDD 

Director 1-8O0.322.2O20 

Voice & TDD 



FOR IMMEDIATE RELEASE CONTACT: LORRAINE GREIFF 

DECEMBER 4, 1987 617-727-7400 

PRESS RELEASE 

ANN WAITKUS-ARNOLD APPOINTED CHAIRWOMAN OF DISABLED PERSONS 
ADVISORY GROUP ON NUCLEAR EVACUATION 



AWN WAITKUS-ARNOLD OF PLYMOUTH WAS RECENTLY APPOINTED BY THE 
MASSACHUSETTS OFFICE OF HANDICAPPED AFFAIRS TO BE CHAIRWOMAN 
OF THE DISABLED PERSONS ADVISORY GROUP ON NUCLEAR EVALUATION. 
THE PURPOSE OF THE ADVISORY COMMITTEE IS TO MAKE RECOMMENDATIONS 
TO THE STATE-WIDE TASK FORCE ON CIVIL DEFENSE TO INSURE 
INCLUSION IN EVACUATION PLANNING FOR PEOPLE WHO ARE ELDERLY 
AND /OR DISABLED IN ALL AREAS OF THE STATE NEAR NUCLEAR POWER 
STATIONS. 

THE ADVISORY GROUP CONSISTS OF ADVOCATES WHO ARE DISABLED 
FROM THROUGHOUT THE STATE. IT HAS MET WITH BOSTON EDISON, 
YANKEE ATOMIC, AND THE MASSACHUSETTS CIVIL DEFENSE AGENCY. 
IT IS EXPECTED TO RECOMMEND THE HIRING OF A PROFESSIONAL 
CONSULTANT TO RESEARCH THE DEMOGRAPHICS OF PEOPLE WITH 
DISABILITIES NEAR NUCLEAR POWER PLANTS; TO DETERMINE THEIR 
NEEDS IN THE EVENT OF AN EMERGENCY; TO DETERMINE WHICH PEOPLE 
IF ANY, CANNOT BE EVACUATED; AND TO DETERMINE THE ATTENDENT 
RISKS IN REMAINING WHERE THEY ARE. 

"THIS ADVISORY GROUP IS A CRITICAL FIRST STEP IN THE STATEWIDE 
EFFORT TO DEAL WITH EMERGENCY EVACUATION PROCEDURES FOR ALL 
PEOPLE," ACCORDING TO JIM GLEICH, DIRECTOR OF THE MASSACHUSETTS 
OFFICE OF HANDICAPPED AFFAIRS. 



30 

The Chairman. Mr. Johnson. 

Mr. Johnson. Thank you, Senator for this opportunity to testify 
before the committee. 

My name is Neil Johnson. I'm the chairman of the Duxbury Citi- 
zens Committee on Nuclear Matters, and a member of the Duxbury 
Emergency Response Committee also. I am a registered profession- 
al engineer and have design experience working on nuclear power 
plants as a licensing, environmental and structural engineer. 

I would like to address three areas: switchyard and emergency 
diesel generators, overpressurization failure and direct torus vent- 
ing and stress corrosion cracking. 

First, the switchyard and emergency diesel generators. On No- 
vember 12, 1987, at approximately 2:10 a.m., the Pilgrim nuclear 
power station experienced a complete loss of offsite power, LOOP, 
during adverse Weather conditions. This resulted in a start-up of 
two emergency diesel generators. Prior to the restoration of offsite 
power at 11:15 p.m. on the same day, one of the diesel generators 
had to be shut down, leaving only one diesel generator operating. 
The event was not given a licensee emergency classification by the 
NRC, as the plant was in cold shutdown. 

It was reported that the loss of offsite power was associated with 
icing in the switchyard. I'm concerned that similar problems with 
the plant operating could occur in the future that could result in 
more serious consequences. 

Since June of 1972, there have been 20 instances of loss of the 
345 kv offsite system and four instances of loss of both the 345 kv 
and the 23 kv offsite system. This would be considered four LOOP 
events, L-O-O-P. 

I believe that prior to restart, the NRC should review the switch- 
yard and emergency diesel generators as a system and assure the 
public that the integrity of this system can be maintained under 
adverse conditions. 

Based on the recent diesel generators and switchyard problems, I 
believe that the NRC should require completion of the installation 
of the new 2,000 kw blackout diesel prior to the restart. 

The conclusion of the NRC Augmented Inspection Team review 
of the November 12 incident, the loss of the offsite power was that 
the inoperability of the B emergency diesel generator resulted from 
the performance of maintenance using inadequate or incomplete 
maintenance procedures. 

1 believe that the NRC should assure the public that BECO will 
more aggressively pursue courses of action to mitigate mechanical 
problems such as those experienced on the B emergency diesel gen- 
erator. 

The next topic is on overpressurization failure and direct torus 
venting. 

The Chairman. Let me just briefly ask you what would have 
been the effect if you had a diesel generator fail, if the plant had 
been on-line? 

Mr. Johnson. Had the last diesel generator failed and the plant 
been on-line, it would have been a station blackout. There is — there 
are some emergency batteries that would keep things going for a 
short time. But without offsite power and without the two diesel 
generators, you have a station blackout. 



31 

The Chairman. What does that mean, station blackout? 

Mr. Johnson. That means you don't have power to run the serv- 
ice water system and your systems required for safe shutdown. 

The Chairman. So the systems for safety would have been effec- 
tively shut down; is that what you are saying? 

Mr. Johnson. Yes. There are some batteries that would keep 
things going for a period of time. OK, overpressurization failure 
and direct torus venting. I understand that severe accidents in the 
extreme can generate pressures of more than twice the design pres- 
sure of a Mark I containment structure similar to the one at Pil- 
grim and could cause containment rupture. One core damage pre- 
vention strategy utilized is containment venting of excess pressure 
gradually. I have a sketch attached for those who would like to see. 
This is achieved by bubbling the release from the gas treatment 
system — excuse me, from the reactor dry well through the wet well 
on through the standby gas treatment system, the SBGT, where re- 
maining radioactive iodine and particulates are removed, finally 
venting out through the main plant stack. Incidently, the standby 
gas treatment system remained out of service from 1984 through at 
least 1986 at Pilgrim. 

It is also my understanding that the existing vent duct work as- 
sociated with the standby gas treatment system is of fairly light 
gauge and may be broached in accident venting. Therefore, the in- 
stallation of the direct torus vent system, which provides a direct 
vent path, with heavier gauge pipe around the standby gas treat- 
ment system was proposed at Pilgrim. Installation of this system 
was begun, but not completed due to a lack of approval by the 
NRC. 

I believe that the NRC should be concerned about the effects of 
secondary release of radioactive gas into the reactor building in the 
event of duct work failure. Also, if in the future, the NRC approves 
the direct torus venting system, I believe that they should review 
the operation of the manual override, which would allow the opera- 
tor to manually override switches to allow venting to continue even 
with high radiation in the torus vapor space. I know that's fairly 
technical, but 

The Chairman. That is very technical. [Laughter.] 

I'll give you 30 seconds to translate it for everyone. Let's just 
take a minute and give us the essence of it, if you would. 

Mr. Johnson. OK. With a station blackout, there are spray sys-~^ 
tems that would cool the reactor. However, if those fail due to no 
power or some other problem, then there is direct torus venting or 
a venting out of the dry well portion of the containment through 
the wet well. 

The Chairman. As I understand it, they don't have torus vent- 
ing; they want to have torus venting? 

Mr. Johnson. Yes. They have started installation of torus vent- 
ing which would bypass the standby gas treatment system. That 
has not been given approval by the NRC. 

The Chairman. Edison desired to design a standby system, but 
NRC has not approved that? 

Mr. Johnson. They felt it was conflicting — I forget the exact ter- 
minology. Conflicting safety issues, I think is the terminology. 



32 

The Chairman. Some translate that as possibly the fact that if 
Boston Edison is prepared to put it in, that might suggest that 
others should put it in their plants, and others might not be willing 
to do it. I don't know if that's fair. 

Mr. Johnson. I'm also a bit concerned in that there is a manual 
override in the event of high pressure and high radiation that 
would allow an operator to open a valve to bypass the SBGT and to 
go right out to the atmosphere via the main plant stack. 

[The prepared statement of Mr. Johnson follows:] 



33 



STATEMENT OF NEIL JOHNSON 



Good evening. My name is Neil Johnson, and I,m the Chairman of 
the Duxbury Citizens Committee on Nuclear Matters and a mem.ber ;f 
the Duxbury Emergency Response Comm.ittee. I am a registered 
Professional Engineer and have 13 years of design experience 
working on nuclear power plants as a Licensing, Environmental and 
Structural Engineer. I,d like to address 3 areas - Switchyard 
and Emergency Diesel Generators, Overpressurizat ion Failure and 
Direct Torus Venting and Stress Corrosion Cracking. 

Swit :hyard and Emergency Diesel Generators 



On November 12,1987 at approximately 2:10 AM, the Pilgrir. Nuclear 
Power Station experienced a complete loss of offsite power (LOOP, 
during adverse weather conditions. This resulted in startup of 
the two emergency diesel generators. Prior to the restoration of 
offsite power at 11:15 P.M. on the same day, one of the diesel 
generators had to be shut down leaving only one diesel generator 
operating. The event was not given a licensee Emergency Class- 
ification by the NRC as the plant was in cold shutdown. 

It was reported that the loss of offsite power was associated 
with icing in the switchyard. I am concerned that sir-.ilar 
problems with the plant operating could occur in the future that 
could result in more serious consequences. 



Since June jf 19''2 there have been 20 instances of loss of the 
345 kV offsite system and 4 instances of loss of both the 345 >V 
and the 23 kV offsite systems ( 4 LOOP events ) . 

I believe, that prior to restart, the NRC should review the swit- 
chyard and emergency diesel generators as a system, and assure 
the public that the integrity of this system can be maintained 
under adverse conditions. 

Based on the recent diesel generator and switchyard problems 1 
believe that the NRC should require completion of the installa- 
tion of the new 2000 KW blackout diesel prior to the restart. 

The conclusion of the Augmented Inspection Tea.m review of tr.e 
November 12, 1987 loss of offsite power was that the ir.- 
operability of the "B" emergency diesel generator resulted frorr. 
the performance of maintenance using inadequate or incomplete 
maintenance procedures. 

I believe that the NRC should assure the public that BECO will 
m^ore aggressively pursue courses of action to mitigate mechanical 
problems such as those experienced on the "B" e.mergency diesel 
generator? 



34 



Overpressure Failure and Direct Torus Venting 

I understand that severe accidents in the extreme can generate 
pressures of T.ore than twice the design pressure of a Mark I con- 
tainment structure similar to the one at Pilgrim and could cause 
containment rupture. One core damage prevention strategy util- 
ized IS containm.ent venting of excess pressure gradually. (see 
attached sketch) . This is achieved by bubbling the release from 
the reactor drywell , through the wet well, on through the Standby 
Gas Treatment System (SBGT) where remaining radioactive iodine 
and particulates are removed, finally venting out through the 
main plant stack. Incidentally, the Standby Gas Treat.-p.ent System 
remained out of service from 1984 through at least 1985 at 
Pilgrim. 

It is also my understanding that the existing vent ductwork as- 
sociated with the Standby Gas Treatment System is of fairly light 
gague and may be broached in accident venting. Therefore the 
installation of a Direct Torus Vent System which provides a 
direct vent path, with heavier gauge pipe, around the Standby Gas 
Treatment System, was proposed at Pilgrim. Installation of this 
system, was begun but not completed due to a lack of approval by 
the NRC. 

I believe that the MRC should be concerned about the effects of 
secondary release of radioactive gas into the reactor building in 
the event of a ductwork failure. Also, if in the future the MRC 
approves the Direct Torus Venting System, I believe that they 
should review the operation of the raanual overide which would al- 
low the operator to manually overide switches to allow venting to 
continue even with high radiation in the Torus vapor space. 



35 




36 



stress Corrosion Cracking 



The 1987 update of the summary of findings and recommondations in 
the Reed Report - 19''5 - General Electric Corporation states that 
stress corrosion cracking ( SCC ) is a complex, industry-wide 
problem affecting both BWR ' s and PWR ' s , and relates fundamentally 
to the harsh environment in which components and piping must 
operate in nuclear power plants. 

In December of 1983, the NRC ordered the lisensee to shut down 
and inspect the recirculating system piping for mtegranular 
stress corrosion cracking. The licensee replaced the recirculat- 
ing system piping and was authorized to restart in December 1984. 

I recommend that the NRC make sure that all recommendations by 
General Electric to upgrade BWR reliability as i.mpacted by stress 
corrosion cracking have been implemented at Pilgrim so that this 
condition does not reoccur in the future. 



37 



Questions 

In The restart plan reference is made to the fact that 4 shifts 
of operators will be available during startup and power ascension 
and that 6 shifts will be available in the longer term. Since 4 
shifts are not able to cover the work week of 21 shifts without 
regular use of overtime ( 50 % overtime ) , how soon will Edison 
have 6 shifts available? 

Would the NRC please obtain and make available to the public the 
records of hours worked by the operators on duty on November 12, 
1987. A two week period prior to and including November 12, 1987 
would be appropriate. 

The restart plan states that "It is not intended as a go/no go 
acceptance criteria. They may proceed if their performance falls 
reasonably within a goal?" Who determines if their performance 
falls within a goal and what criteria is used? 

V/e would like the NRC to discuss decommissioning costs and 
methods. How can we be assured that deccmmissioning will be 
adequately funded for Pilgrim I when it has outlived its 
usefulness? What lessons has the NRC learned from the Ship- 
pingport Pa. decommissioning? 

What will the NRC do to insure that groundwater ingress both 
through the seams in the Process Building wall and through the 
conduit penetration for the switchyard sump pump is corrected? 



38 

The Chairman. OK. We'll go to Mary Ott. We're trying to open 
up the back here so that we can have some of our other guests go 
up on the stage. It might be somewhat uncomfortable, but at least 
they'll be able to observe. 

I'm informed that there is another room here where they are 
covering this through a TV monitor, I'm informed the back is 
loaded with equipment. I don't know where the fire marshall is, 
but we'll check. Anyway, we'll move on. 

Mary Ott, we'll hear from you. 

Ms. Ott. Good evening. Senator Kennedy. We commend you for 
calling this important meeting and are very grateful for the oppor- 
tunity to express our deepening concern about the health and 
safety impact with the restart of Pilgrim, and further at the failure 
of the Nuclear Regulatory Commission to perform its sanctioned 
duty to regulate this utility. 

Our concerns encompass Pilgrims flawed GE Mark I contain- 
ment, its poor management history, the lack of evacuation plans 
for area residents, the threat posed by the continued stockpiling of 
tons of nuclear waste on site, the alarming increase in cancer in 
the five towns downwind, and finally, the credibility of the Boston 
Edison Co. and its regulator, the NRC. 

Although a conclusive link has not been found. Pilgrim's history 
has heightened suspicion of the connection between the plant and 
increased cancer incidents in surrounding communities. The State 
Department of Public Health confirmed this increase in 1986. 

Because the report was criticized for omitting crucial data, a new 
study was promised, which was to include more recent data, causal 
factors, occupational risks and study of cancer incidence in commu- 
nities near nuclear powerplants in New England. This study should 
be completed before Pilgrim is allowed to restart. 

Pilgrim's poor management has been a serious concern since the 
plant was licensed in 1972. Edison's decision to use known defective 
fuel resulted in widespread contamination of the plant and contrib- 
uted to their inability to control iodine releases during the early 
1970's. They subsequently applied to the NRC for a revision of spec- 
ifications to provide for, quote, "operational flexibility", end quote. 
It was granted. 

Following Edison study findings in 1982, the NRC assigned spe- 
cial priorities to monitoring the management of Pilgrim. By 1986, 
16,000 hours of inspection time had been spent at Pilgrim, and a 
third resident inspector assigned. This is 50 percent more inspec- 
tion hours than spent in similar plants in the northeast, a peculiar 
commitment of resources to oversee a plant that the NRC keeps as- 
suring us has always been operated in a safe manner. 

Following Edison — oh, excuse me. Still the problems persist. 
Since 1984, about 100 mishaps have occurred at Pilgrim; 12 acci- 
dents have occurred since 1982, causing Edison to notify state offi- 
cials and police. Despite the objections of State Secretary of Public 
Safety, 22 legislators and concerned residents, Edison refueled the 
reactor with no evacuation plan in place and without notifying the 
appropriate authorities. 

They also commenced the refueling on the very day they assured 
the press that the procedure would be done a week later. When 
questioned about the contradiction, the NRC responded, quote, "if 



39 

the utility lied to the public or to reporters, there is no authority 
under the Atomic Energy Act for the NRC to do anything about it. 
There is no law that says they have to tell reporters the truth," 
end quote. 

In November of 1987, a series of spills and leaks resulted in the 
contamination of several workers. Edison's vice president was in 
Florida at the time. There was no NRC resident inspector on site. 
Plant spokesmen originally denied any leaks, and then later ac- 
knowledged them. Later a single generator was the only source of 
electricity to provide cooling for the loaded reactor. If the plant 
had been operating and that generator failed, we would have had 
to implement the evacuation plan that we do not have. 

Something is wrong here. Senator. Boston Edison has withheld 
documents from the public document room with the permission of 
the NRC. Many missing have been obtained through the Freedom 
of Information Act and chronicle a history of unmonitored releases 
to our environment. Edison continues to tell us that there has been 
no releases in excess of technical specifications. The NRC has not 
made any attempt to contradict the known misinformation. 

During the last 18 months, we have been assured by the NRC 
and the industry that nuclear power has defense in depth, and 
we're often reminded that there are inherent risks associated with 
all forms of energy. The risks we are being asked to bear are unac- 
ceptable. 

Since local and State officials are powerless to resolve our dilem- 
ma and the NRC refuses to hear our requests for a legal hearing, 
we appeal to your committee to initiate an independent, congres- 
sionally sponsored investigation into the health and safety impact 
of the operation of Pilgrim, and further into the conduct of the Nu- 
clear Regulatory Commission. Only a legal inquiry can provide the 
truth about Pilgrim's troubled history. Such a hearing is needed if 
public confidence in our system and in the NRC is to be restored. 
Thank you, Senator. 

[The prepared statement of Ms. Ott (with attachments), follows:] 



40 



TESTIMONY OF MARY C. OTT, CO-CHAIRMAN, DUXBURY 
CITIZENS URGING RESPONSIBLE ENERGY (CURE) BE- 
FORE THE U.S. SENATE COMMITTEE ON LABOR AND 
HUMAN RESOURCES, JANUARY 7, 1988. 

Senator Kennedy, members of the Senate committee, my name is Mary Ott and 1 am the Co- 
Chairman of Duxbury Citizens Urging Responsible Energy. We commend you for calling this 
important meeting, and are grateful for the opportunity to express our deepening concern 
about the health and safety impact of the restart of the Pilgrim Nuclear Power Station and fur- 
ther, at the failure of the U.S. Nuclear Regulatory Commission (NRC) to perform its sanction- 
ed duty to regulate this utility. 

Our concerns encompass Pilgrim's flawed GE Mark I containment; its poor management 
history; the lack of evacuation plans for area residents; the threat posed by the continued stock- 
piling of tons of nuclear waste on site; the alarming increase of cancer in the five towns down- 
wind; and finally the credibility of the Boston Edison Company and its regulator, the NRC. 

Although a conclusive link has not been found. Pilgrim's history has heightened suspicion of 
the connection between the plant and increased cancer incidence in surrounding communities. 

The State Department of Public Health confirmed this increase in 1986. Because the report 
was criticized for omitting crucial data, a new study was promised which is to include more re- 
cent data, causal factors, occupational risks, and a study of cancer incidence in communities 
near nuclear power plants in New England. This study should be completed before Pilgrim is 
allowed to restart. 

Pilgrim's poor management has been a serious concern since the plant was licensed in 1972. 
Edison's decision to use known defective fuel resulted in widespread contamination of the 
plant, and contributed to their inability to control Iodine releases during the early '70's. They 
subsequently applied to the NRC for a revision of technical specifications* to provide for 
"operational flexibility." It was granted. 

Following Edison's precedent-setting $550,000 fine in 1982, the NRC assigned special priori- 
ty to monitoring the management of Pilgrim. By 1986, 16,000 hours of inspection time had 
been spent at Pilgrim and a third resident inspector assigned. This is SO'yo more inspection hours 
than spent at similar plants in the Northeast. A peculiar commitment of resources to oversee a 
plant that the NRC keeps assuring us has always operated in a safe manner. 

Still, the problems persist. Since 1984, about /oo mishaps have occurred at Pilgrim.* 
Twelve accidents have occurred since 1982, causing Edison to notify state officials and police. 

Despite the objections of the State Secretary of Public Safety, 22 legislators and concerned 
residents, Edison refueled the reactor with no evacuation plan in place and without notifying 
appropriate authorities. They also commenced the refueling on the very day that they assured 
the press that the procedure would be done a week later. When questioned about the contradic- 
tion, the NRC responded, "If the utility lies to the public or to reporters, there is no authority 
under the Atomic Energy Act for the NRC to do anything about it. There is no law that says 
they have to tell reporters the truth."* 

In November a series of spills and leaks resulted in the contamination of several workers. 
Edison's Vice President was in Florida at the time. There was no NRC resident inspector on 
site. Plant spokesmen originally denied any leaks, then later acknowledged them. 

•BECO letter to NRC dated May 22. 1975 

•South Look, Karl Abraham, Region I, NRC, Oct. 6-8. 1987 



41 



The plant experienced a complete lost of offsite power for 21 hours. A single generator was 
the only source of electricity to provide cooling to the loaded reactor. If the plant had been 
operating, and that generator failed, we would have had to implement the evacuation plan thai 
we do not have. 

Something is wrong here. Boston Edison has withheld documents from the public document 
room with the permission of the NRC. Many missing have been obtained through the Freedom 
of Information Act and chronicle a history of unmonitored releases to our environment. 
Edison continues to tell us that there have been no releases in excess of technical specifications. 
The NRC has not made any attempt to contradict the known misinformation. 

During the last 18 months, we have been assured by the NRC and the industry that nuclear 
power has "defense in depth," and are often reminded that there are inherent risks associated 
with all forms of energy. The risk we are being asked to bear is unacceptable. 

Since local and state officials are powerless to resolve our dilemma, and the NRC refuses to 
grant our request for a legal hearing, we appeal to your committee to initiate an independent, 
Congressionally-sponsored investigation into the health and safety impact of the operation of 
Pilgrim; and further, into the conduct of the Nuclear Regulatory Commission. 

Only a legal inquiry can provide the truth about Pilgrim's troubled history. Such a hearing is 
needed if public confidence in our system, and the NRC, is to be restored. 

Thank you. 



Postscript: CURE Co-Chairman, Dr. Donald M. Muirhead Jr. and his associate Dr. Belton 
Burrows have submitted additional written testimony regarding the health effects of radiation. 



42 



/.;( CA 



y^r^.5-^.2/j.- y^J't/ 



dOBTON CotsoN Company 

r««Cu»"*f 0'r-Ct« 

aOO BovLflTOH S*aCCT 
aoaTOM. H^cVACMuirrra 02I99 



•^0 



Qt%. 



Director 

Division of Reactor LI' —<"!•. 
Office of Nuclear Ren '"r Regulation 
U.S. Nuclear RoRulat Coimlssloi 
U.ishlnpton, D.C. 20555 



Mjy 22, 1975 ,^ ',h 




Di., et No. 50-293 
License DPR-35 



Subject: Proposed Revision to Airborne Effluents 

Technical Specification for PilRrlni Unit CI 

Dr.Tr Sir: 



iipcr.itlon of PilRrin N'uclear Power- Scat ion In accordance with the present 
Technical Specifications has revealed that section 3.8. B. 2 of the speclflca- 
ilons should be revised to more accurately describe the Intent of the 
specification ind provide operational flexibility. Accordingly, Bi ton 
Ccison Conpany hereby requests that the attached proposed revlslor to 
r^nlinic.il Specif Ic.nlon pages 179. 179A, 179B, 191A and 191B be lued Co 
provide the necessary r larlf Icaclor. and definition. 

This submittal has been approved by the Onslte Review Committee but has not 

been reviewed by the Nuclear Safecy— Review tnd Audit Conmlrtee (NSRAC). 

SSRAC review is underway and will be compleced during the week bep.lnnlng 
May 27, 1975. 

This proposed Technical Specification muse be considered Cemporary since It 
does not reflect the requirements contained In Che new Appendix I Co 10 CFR 50 
Issued by the Connlsslon on April 30, 1975 (and published In Che Federal 
Reglscer, Voluoe 40, No. 87, May 5, 1975). Boston Edison will propose further 
revisions to the Technical Specifications on effluent releases In accordance 
with the new Appendix I not later than June 4, 1976. 



Conronucilth of Massachusetts) 
County of Suffolk ; 



VeiO crul; 



your 




w^suR 



rhen personally appeared before me Francis M. Staszesky, who, being duly sworn, 
did state Chat he Is Executive Vice President of Boscon Edison Company, Che 
applicant herein, and that he is duly authorized to execute and file Che 
proposed Technical Specification revisions described herein in Che name and 
on behalf of Boston Edison Company and Chac the staternentfl In nald proposed 
revisions are true to the best of his knowledge and belief. ^ .yY 



My Ccmimiaslon expires: 



Notary Publ'c 



DMC n SI.-vii r-v 



y 



43 



59 



TABLE 2 



LER SYNOPSIS (11/01/85 - 01/31/87) 
PILGRIM NUCLEAR POWER STATION 



LER 
NUMBER 


EVENT 
DATE 


CAUSE 
CODE 


85-028-00 


10/10/85 


X 


85-029-00 


10/18/85 


X 



85-030-00 


10/30/85 


X 


85-031-00 


10/29/85 


X 


85-032-00 


11/25/85 


B 


85-033-00 


11/27/85 


X 


85-034-00 


12/31/85 


B 


86-001-00 


01/06/86 


A 


86-002-00 


01/16/86 


X 


86-003-00 


02/11/86 


E 


86-004-00 


02/20/86 


X 


86-005-00 


03/07/86 


B 


86-006-00 


03/16/86 


B 



SUMMARY DESCRIPTION 

INADEQUATE SURVEILLANCE PROCEDURE 
FOR STANDBY GAS TREATMENT SYSTEM 

HIGH PRESSURE COOLANT INJECTION 
SYSTEM AND ANTICIPATED TRANSIENT 
WITHOUT SCRAM SYSTEM INVERTERS 
INOPERABLE 

INADEQUATE RECIRCULATION PUMP 
START PROCEDURE 

FAILURE TO MEET MINIMUM SHIFT 
CREW COMPOSITION 

MAIN STEAM LINE HIGH FLOW SWITCH 
SETPOINT DRIFT 

MAIN STACK AND RBV MISSED 
SURVEILLANCE TEST 

TECHNICAL SPECIFICATION REQUIRED 
FIRE DAMPERS FOUND DEGRADED 

UNPLANNED REACTOR SCRAM ON LOW 
WATER LEVEL DUE TO OPERATOR ERROR 

REACTOR SCRAM DUE TO PRESSURE 
SWITCH SENSITIVITY 

480 V SAFETY BUS INADVERTENTLY 
DEENERGIZED DURING MAINTENANCE 

STANDBY LIQUID CONTROL SYSTEM 
DECLARED INOPERABLE WHEN ^ 
SQUIB VALVES NOT TESTED INSITU 

HEAD SPRAY PIPING LEAK IN TORUS 
ROOM 

WELD LEAK ON REACTOR WATER LEVEL 
INSTRUMENT LINE 



44 



60 



LER 

NUMBER 


EVENT 
DATE 


CAUSE 
CODE 


86-007-00 


03/22/86 


X 


86-008-00 . 


04/04/86 

m 


X 


86-009-00 


04/11/86 


X 



86-010-00 


04/15/86 


X 


86-011-00 


04/19/86 


X 


86-012-00 


05/16/86 


X 


86-013-00 


05/30/86 


B 


86-014-00 


06/10/86 


X 


86-015-00 


06/13/86 


X 


86-016-00 


06/21/86 


E 


86-017-00 


07/01/86 


X 


86-018-00 


06/29/86 


X 


86-019-00 


07/15/86 


X 


86-020-00 


08/20/86 


D 



SUMMARY DESCRIPTION 

MAIN STEAM LINE ISOLATION WHILE 
REACTOR SHUTDOWN 

REACTOR SCRAM AND MAIN STEAM 
ISOLATION VALVE (MSIV) RESET 
PROBLEMS 

IN SERIES PRIMARY CONTAINMENT 
ISOLATION VALVES M0-1001-28B 
AND 29B INDICATING LEAKAGE PAST 
SEATS 

MAIN STEAM LINE ISOLATION WHILE 
REACTOR SHUTDOWN 

LEAKAGE PAST MSIV'S IN EXCESS 
OF LLRT CRITERIA 

INSUFFICIENT ONCE/CYCLE HPCI 
SURVEILLANCE PROCEDURE 

USE OF NON-SEISMIC GENERAL 
ELECTRIC TYPE CFO RELAYS 

INSUFFICIENT ONCE/CYCLE RCIC 
SURVEILUNCE PROCEDURE 

PRIMARY CONTAINMENT LOCAL LEAK 
RATE TESTS OVERDUE 

BUS A5, BUS A6 AND STARTUP 
TRANSFORMER DEGRADED VOLTAGE 
RELAY CALIBRATIONS OVERDUE 

CONTAINMENT ISOLATION VALVE 
LOCAL LEAK RATE TEST FAILURES 

GENERAL ELECTRIC AKF FIELD 
BREAKER FAILED TO TRIP 
AUTOMATICALLY 

INSUFFICIENT MONTHLY ATWS 
SURVEILLANCE PROCEDURE 

UNIDENTIFIED FIRE BARRIER WALLS 
AND PENETRATIONS 



45 



61 



LER EVENT CAUSE 

NUMBER DATE CODE SUMMARY DESCRIPTION 

86-021-00 08/27/86 B STANDBY GAS TREATMENT SYSTEM /^ 

DELUGE SYSTEM SINGLE FAILURE ^ 
MODE 

E MISSED TECHNICAL SPECIFICATION 
SOURCE LEAK CHECK SURVEILLANCE 

A MISSED FIRE WATCH AND FIRE 
WATCH PATROLS 

X NON FIRE RESISTANT COATED 
STRUCTURAL STEEL 

B MISALIGNMENT OF THE FIRE 
SUPPRESSION WATER SYSTEM 

D FAILURE TO PERFORM RADIO- 
ACTIVE MATERIAL SURVEILLANCE /^ 
TEST OF STANDBY GAS TREATMENT 
SYSTEM AND LIQUID RAD. EFFLUENT 
MONITOR 

C LOSS OF OFFSITE POWER DUE TO 
SEVERE WINTER STORM 

86-028-00 12/23/86 X FAILURE TO RECOGNIZE THE EFFECTS 

OF ELECTRICAL ISOLATION RESULTING 
IN ESF ACTUATION 

86-029-00 12/23/86 X LOSS OF OFFSITE POWER WHILE WASHING 

SALT FROM YARD INSULATORS 



86-022-00 08/29/86 



86-023-00 09/12/86 



86-024-00 10/07/86 



86-025-00 11/11/86 



86-026-00 10/29/86 



86-027-00 11/19/86 



NOTE: 

There is no published synopsis of Licensee Event Reports 
for 1987 at this time. Per the Librarian, Grace Karbot, 
in the Plymouth Public Document Room, 19 such events 
did occur in 1987. 



1984 


20 


1985 


34 


1986 


29 


1987 


19 



TOTAL 



102 



46 



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47 



Page 1 



QUESTIONS FOR INCLUSION IN CONGRESSIONAL RECORD OF JAN. 
7, 1988 hearing on the restart of the Pilgrim Nuclear 
Power Plant 

submitted by Citizens Urging Responsible Energy 

HEALTH ISSUE: 

1. What is the reason for the State's failure to investigate 
Boston Edison's alleged dumping of radioactive materials 

on their property^in Plymouth? (promised in Aug., 1987) 

2. Boston Edison has admitted to dumping radioactive 
.material at the Plymouth town dump site. Do state and 
|federal regulations permit such action? Are not Plymouth 

■residents exposed to radiation when using the dump? 

3. Massachusetts is the nation's fifth largest producer 
of low-level nuclear waste. (100,000 cubic feet) What 
portion of that waste is generated by Pilgrim? How does 
that compare with similar size plants of the same design? 

4. After the radioactive leaks in Nov., 1987, CURE requested 
that air sampling and soil testing be done by the Mass. Dept. 
of Public Health. The state agreed to the undertaking, but did 
not do it. Who decided that this was not necessary? 

5. Almost 2 years have elapsed since the State promised to 
redo and upgrade the health study of high cancer incidence 
in the 5 towns downwind of Pilgrim. What is the current 
status of the study? Does the state feel that the issue of a 
possible conclusive link between adverse health effects and 
Pilgrim should be resolved before the plant's restart? 

6. Boston Edison undertook a study of their employees' and 
former employees' health status. Is this study completed? 
Does it have preliminary findings? Will it be shared with 
the MDPH? 

7. What were the NRC and state radiation monitoring readings 
in June, 1982 when highly radioactive resin was blown out 

a 100 ft. duct and deposited on roof tops and paved areas at 

Pilgrim? (all readings: onsite, stack, offsite) 

Was data retrieved from dosimeters at all locations? 

8. CURE reported allegations to the NRC last summer regarding 
the removal of shrubbery onsite at Pilgrim which was said to be 
radioactive. The NRC said that the licensee stated the bushes 
were removed for security reasons. They later admitted that 
there was some amount of radioactivity and would investigate 
the matter. How do bushes at Pilgrim become radioactive? 
Where were they taken? Were appropriate surveys conducted? 



48 



QUESTIONS ON HEALTH ISSUE, CONT'D Page 2 



9. NRC: Please interpret, based on the Sandla report, 
the expected number of deaths and casualities, long and 
short-term, which would result from an accident at Pilgrim, 
(in laymen's terms) 

10. NRC: Can you provide figures on the increase of 
background radiation over the last 15 years? (in laymen's terms) 
What percentage of the increase is attributed to man-made 
radioactive nuclfdes (i.e. cesium 137, I 131, strontium 90, 
etc.)? Are figures available locally and nationally? 

What are the present figures for natural background radiation 
(i.e. solar rays, etc.)? 

11. NRC: Has Boston Edison ever exceeded technical speci- 
fications on radioactive releases from Pilgrim? 

On what dates, and in what amounts over specification? 

Are there fines or violations associated with such releases? 



49 



Page 3 



QUESTIONS FOR INCLUSION IN CONGRESSIONAL RECORD OF JAN. 
7, 1988 hearing on the restart of the Pilgrim Nuclear 
Power Plant 

submitted by Citizens Urging Responsible Energy 

FIRE PROTECTION: 

1. Is BECO now in full compliance with Appendix R require- 
ments in fire protection? Have they applied for any waivers? 

2. Are all barriers, fire doors and penetration seals 
repaired and capable of passing required testing? 

3. In Feb., 1986 72 locations at Pilgrim were being observed by 
fire watches because of unfinished maintenance in the area of fire 
protection. How many were being observed on Jan. 1, 1988? 

4. Is the water pressure from the town of Plymouth adequate 
to fight a fire on the second floor of Pilgrim Station? 

5. The Standby Gas Treatment deluge system has been reported 
to be inoperative since 1984 because it requires an outage 

to test it. Has this matter been resolved during the current 
outage? If not, why not? 

6. The Halon system in the computer room is reported to have 
been inoperable since March, 1985 because there is no pro- 
cedure to test it. Why isn't there a procedure? When will 
there be one? 

7. What procedures are in place to suppress a fire in the 
computer room since the halon system in inoperative? 

8. The smoke detectors over the spent fuel pool have been 
inaccessible to test since May, 1984. BECO is said to be 
investigating acquiring a compact scissors lift to test to 
test these and other inaccessible detectors in April, 1986. 
Has it been acquired? Have they been tested since that time? 

9. BECO documents reveal that some outstanding maintenance 
requests (mrs) in the area of fire protection which were 
established several years ago have been assigned 1987 m.r. 
numbers giving the impression that they represent newly 
identified problems. Please list outstanding mr . in this area, 
and the dates each m.r. was established. 

10. CURE received a report that Pilgrim's onsite fire 
brigade was activated to investigate the sound of a small 
explosion and the smell of "something burning" on Nov. 12th 
at the time of the power loss. Evidence has been shown to 
Department of Public Safety and the Senate Committee. 

The NRC and BECO continue to deny these reports. What pro- 
cedures were used by the NRC to investigate this allegation? 
Did onsite NRC inspectors question employees who would have 
been assigned to the brigade at that tinie? 



50 

Page 4 



QUESTIONS FOR INCLUSION IN CONGRESSIONAL RECORD OF JAN. 
7, 1988 hearing on the restart of the Pilgrim Nuclear 
Power Plant 

submitted by Citizens Urging Responsible Energy 
GENERAL SAFETY: 

1. Did BECO shut Pilgrim down voluntarily on April 11, 1986, 
or did the NRC shut them down? 

2. Is the Confirmatory Action Letter (CAL) still in effect? 

3. Was -unusual event" the proper declaration for the emergency 
at Pilgrim which began on April 10, 1986? NUREG-0654, page 1-9, 
item 4. classifies a Main Steam Isolation valve malfunction 
causing leakage as an "alert declaration." 

4. Was the emergency in April caused by a recurring GE design 
problem with the Main Steam Isolation Valves? 

5. On Oct. 29, 1987 at the Duxbury forum, BECO claimed to 
have resolved the main steam isolation valve problems which 
have been identified by GE in the Reed report as unresolved 
generic issues. Has this resolution been shared with the NRC or GE. 
Is there documentation of this resolution in published form? 

6 On April 4, 1986, the Residual Heat Removal (RHR) A Loop was 
shut down for repairs. Was the RHR A Loop repaired and operable 
on April 10, 1986? 

7. We have noted no emergency event declarations since the 
shutdown in April, 1986. The NRC says that declaration require- 
ments do not apply to plants that are not operating. ^hy then 
were three inspectors dispatched to New Hampshire and Seabrook 
cited for a violation in procedure for not notifying the state 
of Massachusetts within 15 minutes of the declaration of an 
"unusual event"? 

8. How many scrams (manual and automatic) have occurred at 
Pilgrim since it began operation in 1972? Do scrams con- 
tribute to core embrittlement? What is the industry average? 

9. What tests have been performed to assess any potential 
weakening or embrittlement of the Pilgrim reactor? Who did 
them? What were the results? When were they done? 

10. BECO has spent 30 million dollars on enhancements to 
their GE Mark I containment. Ten million of that amount is 
said to have been spent on a risk assessment study. Does the 
NRC have a copy of this document? Will they share it with 
state officials? 



51 



QUESTIONS ON GENERAL SAFETY, CONT' Page 5 

11. How many "substantial safety hazard" reports (or their 
equivalent) have been generated by Pilgrim since 1972? 
Please define report and list the dates and reasons for such. 
How does Pilgrim's average compare to similar size plants of 
the same design? 

12. How many violations of NRC requirements have taken place 
at Pilgrim since 1972? How does the total compare to similar 
size plants of the same design? 

13. On August 15, 1986, BECO notified the NRC that contrary 
to technical specification requirements, monitoring of the 
primary containment inerting system makeup flow rates had 
not been conducted. (said to detect any large increase in 
containment leakage) They further stated that instrumentation 
used to perform such monitoring had been out of service since 
January, 1985. Did the NRC cite or fine BECO for this vio- 
lation of procedure? Is this instrumentation now functional? 

14. Is the Standby Gas Treatment System activated by a power loss? 

15. If direct torus venting were to be used, what is the 
range of dose rates at the exclusion zone boundary in the event 
of venting? At what pressure would venting take place? 

16. If Pilgrim had been operating on Nov. 12, 1987, and the 
single operating generator had failed, did the potential 
exist for a core-melt accident sequence? (please answer 

yes or no) 

In November, 1987,- 

17. During the power loss CURE received a report that two 
pumper trucks were called onsite at Pilgrim to remove 
excess water from drains. The volume of water was said to be 
be such that it posed back up problems in the plant which 
would activate automatic sump pumps; thereby drawing ad- 
ditional electricity from the single operating generator. 

If the system had not been pumped out before the pumps 
engaged, would an emergency evacuation have occurred? 
Was the NRC informed of this incident? Was the waste water 
contaminated? Was it tested? Where was it taken? 



52 



Page 



QUESTIONS FOR INCLUSION IN CONGRESSIONAL RECORD OF JAN. 
7, 1988 hearing on the restart of the Pilgrim Nuclear 
Power Plant 

submitted by Citizens Urging Responsible Energy 

EMERGENCY PLANNING: NRC, FEMA and State Officials 

1. What agency is liable for damages incurred as a result of 
an improperly implemented evacuation plan? 

2. If a radioactive plume can travel 10 miles per hour, how 
can people evacuate to a proper shelter under adverse weather 
conditions? 

3. Is it true that the planning for the health and safety of 
residents in the EPZ is not based on a worst case scenario event? 

4. Does Duxbury need a 3rd reception center to decontaminate 
evacuees? 

5. BECO'S KLD time estimate study indicates that during a 
major snowstorm, 50% of all driveways will be plowed within 
30 minutes. Vfhat is the basis for that judgement? 

6. NRC: define explicitly the role FEMA'S judgement will 
play in determining the "adequacy" they claim will be required 

in emergency planning before they will grant permission for restart. 

7. FEMA announced withdrawal of approval of Pilgrim's 
evacuation plan on August 6, 1987. The NRC has now exceeded the 
120-day period to make a decision regarding FEMA'S negative 
findings. When will that decision be made? 

8. Why has BECO'S Bus Shelter Survey not been made available 
to communities in the EPZ? 

9. FEMA declined to participate in a forum sponsored by the 
the Duxbury Board of Selectmen on Oct. 29, 1987 because of a 
prior commitment and said therft^ staff ' s time was consumed 

with the Seabrook issue. Does FEMA give preference to licensing 
over safety issues? 

10. What provisions have been made to segregate the prisoners 
at the Plymouth County House of Correction from other people 
evacuating in the case of an emergency at Pilgrim? 

11. Will the NRC make a restart decision regarding evacuation 
planning on potential solutions proposed by BECO, or on completed 
plans which have been verified with letters of agreement and 

approved by the local communities and the Commonwealth of 
Massachusetts? 



53 

The Chairman. Dr. Healy. 

Dr. Healy. Thank you, Mr. Chairman. 

The Plymouth Committee on Nuclear Matters, formally consti- 
tuted by the Board of Selectmen on August 19, 1986, consists of 
nine members of diverse backgrounds and experience, with exper- 
tise in the medical and legal fields; in business and industry, in- 
cluding the utilities; in physics and engineering, in planning and in 
public policy. 

The committee members while differing sometimes radically in 
their opinions have one common passion, that of the discovery of 
what is fact. We have done our best to put aside our individual 
biases in order to listen to knowledgeable others. 

Thus far, the committee has issued two reports. The first on the 
Plymouth Radiological Emergency Response Plan; the second on 
Environmental Radiation Monitoring. In the first report, we said 
the following in March 1987: 

There are deficiencies in the Plymouth Radiological Emergency 
Response Plan which are serious enough in the committee's judg- 
ment to preclude reasonable assurance that adequate protective 
measures can and will be taken by the town and the state in the 
event of a radiological emergency. 

Hence, the committee made the following recommendations: 

1. That there be a comprehensive revision of the Plymouth Radi- 
ological Emergency Response Plan. This task is incomplete. 

2. That there be an appointment made of a full-time civil defense 
director. That individual will begin on January 11, next Monday. 

3. Development of funds for emergency preparedness from Feder- 
al, State and utility sources. The only funds forthcoming have been 
from Boston Edison. 

4. Full town participation in a comprehensive drill prior to Pil- 
grim's coming back on-line. This has not been done. 

Regarding the second committee report, the Committee on Nucle- 
ar Matters is strongly concerned with what it considers to be the 
insufficient number of monitoring stations, the minimal and per- 
functory involvement of the State in the monitory process and the 
complete lack of an oversight monitoring system. 

All of the many reports reviewed by the Committee on Nuclear 
Matters indicate to its members that the Pilgrim nuclear power 
plant does have a continuing environmental impact. In all the ma- 
terials reviewed, however, Edison, NRC and the Commonwealth 
hold that offsite releases from the plant, as indicated by current 
monitoring, have not exceeded technical specifications. 

Boston Edison Co., the NRC and the Commonwealth then draw 
the conclusion that there has been no measurable impact upon the 
citizenry. They further claim that even if there had been any 
impact, it would have been minimal and far less than the effects of 
previous worldwide weapons testing or of the Chernobyl accident. 

The Committee on Nuclear Matters takes little comfort in the 
above comparisons. Any environmental impact is our concern and 
needs to be examined. Let us not forget that the impact of such ef- 
fects is cumulative. The committee questions the adequacy of cur- 
rent monitoring around Pilgrim I, even though it is more extensive 
than that at some other nuclear plants. 



54 

Hence, the committee recommends increased monitoring, higher 
quality monitoring, proper timing of monitoring to reveal effects of 
specific plant incidences which involve radioactive releases and 
prompt reporting of the results. Accomplishment of these recom- 
mendations is basic to an investigation of the impact of the station 
upon citizens' health; an investigation which has yet to be accom- 
plished. 

We respectfully request your assistance, Mr. Chairman, on two 
related matters which may not be the direct concern of your com- 
mittee. We request that you exert your considerable leadership at 
the national level to help mitigate the unintended, negative conse- 
quences of past congressional action and inaction which have led to 
America's hometown becoming, in fact, a high level nuclear dump 
site. We beg you to assist in relieving us of this burden. Only Con- 
gress can do it, not the utilities and not Boston Edison. 

We ask that you monitor closely the progress of the Department 
of Energy's work at the Yucca Mountain drilling site in Nevada to 
insure that the nation will obtain as soon as possible a long, over- 
due, permanent repository for high level nuclear waste. 

We also respectfully suggest that you help to initiate a congres- 
sional review of the role and the performance of the Nuclear Regu- 
latory Commission, and reasserting of congressional authority rela- 
tive to the nuclear industry. It is needed. We request that you in- 
troduce corrective legislation which will ensure congressional au- 
thority and responsibility. 

Thank you very much for this opportunity, Mr. Chairman. It is 
deeply appreciated. I shall be happy to answer any questions inso- 
far as I am able. 

[The prepared statement of Dr. Healy (with attachments) fol- 
lows:] 



55 



TESTIMONY BEFORE THE LABOR AND HUMAN RESOURCES COMMITTEE 

OF THE UNITED STATES SENATE 

(Senator Edward M. Kennedy, Committee Chairman) 

By Dr. Grace M. Healy, Chairman 

COMMITTEE ON NUCLEAR MATTERS 

TOWN OF PLYMOUTH, MASSACHUSETTS 

Thursday, January 7, 1988 

The Plymouth Committee on Nuclear Matters, formally constituted by the 
Board of Selectmen on August 19, 1986, consists of nine members of diverse 
backgrounds and experience with expertise in the medical and legal fields, in 
business and industry including the utilities, in physics and engineering, in 
planning, and in public policy. 

The Committee members, while differing sometimes radically in their 
opinions, have one common passion - that of the discovery of what is fact . 
We have done our best to put aside our individual biases in order to listen 
to knowledgeable others. We have researched facts, gathering available 
information from voluminous written materials and reports, from interviews of 
relevant parties and from public hearings. We have visited the plant, 
participated in simulated emergency and training drills, consulted with 
technical experts and deliberated with one another during lengthy committee 
meetings . 

Our deliberations have, at times, been difficult. In the end, we have 
managed to reach consensus on most recommendations. It is clear that we 
stand together in our concern for the safety of all residents of Plymouth. 

Thus far the Committee has issued two Reports: the first on the Plymouth 
Radiological Emergency Response Plan; the second on Environmental Radiation 
Monitoring. In the first report we said the following in March 1987: 

There are deficiencies in the Plymouth Radiological Emergency Response 

Plan which are serious enough, in the Committee's judgment, to preclude "... 

reasonable assurance that adequate protective measures can and will be taken 

(by the Town and State) in the event of a Radiological Emergency." There is 

reason to believe that as things stand now, the Selectmen cannot fulfill 

their legal responsibility, particularly during a Radiological Emergency, 

".... to provide for the health and safety of persons and their property 
II 

The Plymouth Radiological Emergency Response Plan is a "paper" plan, 
essentially untested relative to mobilization of some of the essential 
personnel. Hence, the Committee made the following recommendations: 

1. Comprehensive revision of the Plymouth Radiological Emergency 
Response Plan. 
This task is not complete. 



56 



Page 2 

2. Appointment of a full-time Civil Defense Director, with staff as 
needed, with adequate interim headquarters, and with long-term 
plans for location in one of the new Town buildings. 

The Civil Defense Director will begin work on January 11. 1988 . 

3. Development of funds for emergency preparedness from federal, state 
and utility sources. 

Only funds from Boston Edison are being made available to the Town . 

4. Full Town participation in a comprehensive drill prior to Pilgrim's 
coming back on-line. 

This has not been done . 

The Committee holds that the Plan must be operat ionalized. Procedures 
must be specified and tested . Commitments of personnel and materials must be 
legally formalized . Anything less is unacceptable. 

Regarding the second Committee Report: 

The Committee on Nuclear Matters, in an attempt to understand the 
monitoring of environmental radiation associated with the Pilgrim Nuclear 
Power Station, reviewed documents provided by Boston Edison and interviewed 
knowledgeable persons, including but not limited to Boston Edison 
representatives. Nuclear Industry representatives. Department of Public 
Health representatives and State Officials. 

The Committee on Nuclear Matters is strongly concerned with what it 
considers to be the insufficient number of monitoring stations, the minimal 
involvement of the State in the monitoring process, and the complete lack of 
an "oversight" monitoring system. 

All of the Reports reviewed by the Committee on Nuclear Matters (1982- 
1987) indicate to its members that the Pilgrim Nuclear Power Plant does have 
a continuing environmental impact. In all of the materials reviewed, 
however, Boston Edison Company, the N.R.C., and the Commonwealth bold that 
offsite releases from the Plant (as indicated by current monitoring) have not 
exceeded technical specifications. Boston Edison Company, the N.R.C., and 
the Commonwealth then draw the conclusion that there has been no measurable 
impact upon the citizenry. They further claim that even if there had been 
any impact it would have been minimal, and far less than the effects of 
previous worldwide weapons testing or of the Chernobyl accident. 

The Committee on Nuclear Matters takes little comfort in the above 
comparisons. Any environmental impact is of concern and needs to be examined 
if public health is to be protected. Let us not forget that the impast of 
such effects is cumulative! The Committee questions the adequacy of current 
monitoring around Pilgrim I, even though it is more extensive than that at 
some other nuclear plants. Hence, the Committee recommends increased 
monitoring, higher quality monitoring, proper timing of monitoring to reveal 
effects of specific plant incidences which involve radioactive releases, and 
prompt reporting of the results. Accomplishment of these recommendations is 
basic to an investigation of the impact of PNPS upon citizens' health . . . an 
investigation which has yet to be accomplished. 



57 



Page 3 

The two Committee Reports mentioned here are being made available to 
your staff, Mr. Chairman, as will be future reports and recommendations from 
our Committee. 

We respectfully request your assistance on two related matters which may 
not be the direct concern of your Committee. We request that you exert your 
considerable leadership at the national level to help mitigate the unintended 
negative consequences of past Congressional action and inaction which have 
led to America's Home Town becoming, in fact a high level nuclear dump site. 
We beg you to assist in relieving us of this burden. Only Congress can do 
it, not the utilities - not Boston Edison. 

We ask that you monitor closely the progress of the Department of 
Energy's work at the Yucca Mountain drilling site in Nevada to insure that 
the nation will obtain as soon as possible a permanent repository for high 
level nuclear waste. 

We also respectfully suggest that you help to initiate a Congressional 
review of the role and performance of the Nuclear Regulatory Commission, and 
the reasserting of Congressional authority relative to the Nuclear Industry. 
If it is needed, we request that you introduce corrective legislation which 
will ensure Congressional authority and responsibility. 

Thank you very much for this opportunity, Mr. Chairman; it is deeply 
appreciated. I shall be happy to answer any of your questions insofar as X 
am able. 



58 



TOWN OF PLYMOUTH 

COMMITTEE ON NUCLEAR MATTERS 



REPORT TO THE SELECTMEN 

ON 

THE PLYMOUTH RADIOLOGICAL EMERGENCY RESPONSE PLAN 



March, 1987 



MEMBERS : 



59 



THE COMMITTEE ON NUCLEAR MATTERS 



Grace M. Healy, Chair 
Charles W. Adey, Vice-Chair 
Ann Waitkus Arnold 
Theodore L. Boeen 
Marie P. Fehlow 
Kenneth T. Holmes 
Kathleen M. Leslie 
Anthony V. Lonardo 
John P • Rooney 
James W. Ryan 
Howard E. Shetterly 



SUBCOMMITTEE MEMBERS: 



Ann Waitkus Arnold 
Kenneth T. Holmes 



60 



TOWN OF PLYMOUTH 

THE RADIOLOGICAL EMERGENCY RESPONSE PLAN 

INTRODUCTION 

As one of its tasks, the Committee on Nuclear Matters assumed respon- 
sibility for a review of the Plymouth Radiological Emergency Response Plan 
(RERP). The following is the result of research undertaken by the sub- 
committee, and of the deliberations of the entire committee. 

In order to determine Plan adequacy and feasibility, information was 
sought from many sources. Subcommittee members reviewed written materials: 
other Emergency Response Plans (ERP); Federal Emergency Management Agency 
(FEMA) Regulations; reports on the adequacy of various RERP's; testimony of 
public interest groups, and one available section of Secretary Barry's 
report. Subcommittee members also contacted, in person and by telephone, 
representatives from: (1) Local, Regional and State Civil Defense Offices, 
(2) FEMA, (3) various Town Offices; (4) State Office of Handicapped Affairs; 
and (5) Boston Edison. 

SUMMARY CONCLUSIONS AND RECOMMENDATIONS 

There are deficiencies in the Plymouth RERP. Moreover, these 
deficiencies are serious enough, in the Committee's judgment, to preclude 
"... reasonable assurance that adequate protective measures can and will be 
taken (by the Town and State) in the event of a Radiological Emergency." 
There is reason to believe that as things stand now, the Selectmen cannot 
fulfill their legal responsibility, particularly during a Radiological 
Emergency, ".... to provide for the health and safety of persons and their 
property . . . ." 

The Plymouth RERP is a "paper" plan, essentially untested relative to 
mobilization of some of the essential personnel. As long as it is untested, 
difficult questions can remain unanswered and difficult decisions can be 
avoided. This is a situation unacceptable to the members of the committee. 
Thus, we respectfully urge Selectmen to assign tasks and timelines to 
appropriate personnel and/or offices to ensure accomplishment of the 
following : 

A. Comprehensive revision of the Plymouth RERP. 

1. Correction of outdated information. 

2. Elimination of specific deficiencies noted below. 

3. Complete specification of implementation procedures. 

4. Specification of procedures for ongoing updating and 
coordination with local, area, and state plans. 

B. Appointment of a full-time Civil Defense Director, with staff as 
needed, with adequate interim headquarters, and with long-term plans for 
location in one of the new Town buildings. 

C. Development of funds for emergency preparedness from federal, state 
and utility sources. (Appointment of liaison for same.) 



61 



D. Full Town participation in a comprehensive drill prior to Pilgrim's 
coming back on-line. (While actual citizen evacuation may not be feasible, 
full participation must at least include all responsible personnel being in- 
£lace and carrying out assigned tasks.) Coordination of agencies, their 
services and lines of responsibility - local, state, federal levels must be 
test ed . 

The Committee further recommends that all deficiencies be remedied and 
all recommendations be implemented prior to reactor start-up. 

There was one dissenting opinion expressed concerning the above. The 
objection relates to making total task accomplishment a condition for reactor 
start-up when longer time may be required for some tasks. The dissenting 
opinion does not represent disagreement on deficiencies or recommendations, 
but on timelines. In all cases there is agreement on need and urgency for 
act ion . 



SPECIFIC DEFICIENCIES AND RECOMMENDATIONS 

Following are specific deficiencies found by the Committee on Nuclear 
Matters and some recommended corrective measures; they have been grouped in 
eight categories: (A) Advance Information, (B) Notification and Communication 
Systems, (C) Evacuation Routes, (D) Evacuation Time Estimates, (E) Transport 
of Dependent Populations, (F) Reception Centers and Public Shelters, (G) 
Medical Facilities, and (H) Radioprotective Drugs. 

A. ADVANCE INFORMATION 
DEFICIENCIES: 

1. Inadequate public information in Emergency Preparedness Zone (EPZ). 

2. Lack of multi-lingual information (Italian, Portuguese, Spanish, 
Japanese) . 

3. Inadequate distribution of Emergency Preparedness Information (EPI) 

brochures . 

4. No information for people without access to transportation. 

5. No information about staging areas (pick-up points). 

6. Tourist and transient information inadequate or non-existent. 

7. No educational effort outside the Town of Plymouth. 



/ 



62 



ADVANCE INFORMATION (Continued) 
RECOMMENDATIONS : 

1. Implement a comprehensive, ongoing public educational program through 
new8 ads, cable TV programs, radio public service announcements, and 
informational packets included in utility bills. Include an outreach 
program for non-English speaking people in these activities. 

2. Develop emergency information posters (multi-lingual), with maps 
explaining: 

- Protective Actions - Location of Public Transportation 

- Evacuation Routes - Local Radio Station of EBS 

- Location of Public Shelters - Staging Area Locations 

3. Post Emergency Information Posters in public locations: 

Hotels, motels, restaurants, gas stations, phone booths, recreation 
facilities, tourist sites, informational centers, theaters, airports, 
bus stations, trolley cars, and all public buildings. 

4. Develop survey to identify special populations: 

a. Non-English speaking people. 

b. Transport dependent groups: 

- 15% of Plymouth households have no car; 

- 50% of households have one car, but one half of workers have jobs 
outside of Plymouth. 

c. Special needs people: 

- Federal regulations require notification of "all segments of 
society." 

- Deaf and hard-of-hearing people must be identified beforehand so 
they can be alerted by appropriate means. 

5. Distribute updated pamphlets semi-annually to: 

- General public and all recommended locations in #3 above. 

- Multi-lingual pamphlets should be available in the same places. 



63 



B. NOTIFICATION AND COMMUNICATION SYSTEMS 
DEFICIENCIES: 

1. Siren System 

a. The siren system is not equipped to confirm that all sirens have 
been sounded during an exercise. There are no provisions for 
determining which sirens are not working. 

b. Present siren system does not warn hearing-impaired persons. No 
alternate plan exists to notify this segment of the population. 

2. Radio Communications 

a. Department of Public Works radio equipment used for Civil Defense 
is unreliable and inadequate. 

b. Present system for notifying local officials is unreliable. 

c. Plymouth County radio network (Sheriff's) is inadequate/ 
inefficient . 

RECOMMENDATIONS: 

ALL PROCEDURES FOR NOTIFICATION OF AN ACCIDENT AT PILGRIM I SHOULD BE 
REVIEWED. 

1. Investigate the "hard-wire" system or other alternatives that confirm 
siren activation. Alert officials who will dispatch personnel to areas 
with defective sirens to activate sirens manually and to warn public 
from vehicles and loudspeakers. 

2. Develop procedures to confirm activation of every siren. Specify 
numbers of vehicles and personnel required for #1 above. 

3. Test sirens weekly on the same day and at the same time. 

4. Identify hearing impaired people and install telecommunication devices. 

5. Provide closed captioning for the Emergency Broadcasting System. 

6. Install tone alert radios in every school bus, transport vehicle, and 
other vehicle specially licensed to transport children, the elderly, and 
handicapped persons in the Emergency Preparedness Zone. 

7. Upgrade Plymouth County Radio network hardware. Test the hardware on a 
regular basis. 



64 



EVACUATION ROUTES - LIMITED ACCESS AND EGRESS 



DEFICIENCIES; 



1. Proposed routes (Routes 3 and 44) are completely inadequate for 
effective handling of anticipated volume of traffic. Traffic is already 
jammed due to the heavy volume of tourists in the summer months, and 
during heavy winter storms, or when roads are under construction or 
repair. 

2. Voluntary evacuation (Evacuation Shadow Phenomenon) is not taken into 
account . 

RECOMMENDATIONS : 

The following are not remedial; they simply address worsening of the 
problem. 

1. New development along evacuation routes should require an impact study 
by developers with specifications set by appropriate Town Offices. The 
study should be reviewed by the Planning Committee. 

2. Prior to approval of road construction/repair (along evacuation routes) 
the appropriate Town Office must make an impact assessment and develop 
alternative routes. 



D. EVACUATION TIME ESTIMATES 



DEFICIENCIES: 



Present time estimates are based on outdated information and have major 
f laws . 



Evacuation Time 
assumptions : 



Estimates (ETE) is based on several questionable 



It assumes there will be no mass voluntary evacuation not in 

planned boundaries (shadow-phenomenon) as occurred at Three Mile 

Island, which could cause major route blockage and back-ups. 

It assumes that emergency personnel will remain in place and not 

evacuate with their families. 

It assumes that communities outside the Ten Mile EPZ have developed 

adequate plans to augment evacuation and sheltering efforts, 

although Massachusetts Civil Defense Agency (MCDA) states no such 

plan exists. 

It assumes the timely presence of State Police and National Guard. 



Large discrepancies exist between 
Regulatory Commission (HRC) ETE's. 



Boston Edison and the Nuclear 



EVACUATION TIME ESTIMATES (Continued) 

4. Panic and traffic disorder have not been adequately considered: 

a. Blocking of cross streets 

b. Disregard of traffic signals 

c. Driving in left hand lane 

d. Abandoned vehicles 

e. Driver confusion 

f. Failure of traffic control 

g. Accidents 

These considerations plus ineffective traffic control could result 
in more than a 50% reduction in traffic flow, which would mean the 
evacuation time could be more than doubled. 

5. No adequate estimates for time required to evacuate non-car-owning 
people dependent on public transport. 

6. Estimates of the number of vehicles at public beaches is inadequate. 

7. Estimates required by federal regulations are lacking. 

a. Separate times for adverse weather - fog, rain, flooding, snow, 
storms . 

b. Day versus night, workday versus weekend, peak transient versus 
non-peak transient, and evacuation versus non-evacuation in 
adjacent sectors. 

c. Separate estimates for "special population groups" on an 
"institution by institution" basis (e.g., schools, hospitals, 
nursing homes, correctional facilities). 

RECOMMENDATIONS : 

1. The new Boston Edison Company (BECo) ETE's must: 

a. be based on realistic assumptions, 

b. include all specific time estimates required by FEMA, 

c. take into account mass voluntary evacuation consequences, 

d. address previously stated shortcomings. 

2. The new £TE must be completed prior to plant operation. 

3. Documentation should be provided by BECo to assure the ETE's provide a 
workable means to evacuate all residents of the EPZ based on a wide 
range of accident scenarios. 



66 



E. FLAMS TO TRANSPORT DEPENDENT POPULATION 

(People without access to cars, school children and children in day 
care, hospital and nursing home residents, handicapped persons, campers, 
persons in correctional institutions.) 

DEFICIENCIES: 

1. Numbers of vehicles needed and sources for them have not been analyzed. 

2. No contracts or letters of agreement have been signed with MBTA, bus 
companies, drivers, ambulance companies, and other entities providing 
public transportation and personnel support for the plan. 

3. There are no particular plans for evacuating handicapped people. This 
segment of the population has not even been identified. 

4. Plans call for individuals to make arrangements with local CD for 
transportation. Local CD will then contact MCDA Area II for assistance; 
however, the Area II plan does not contain information on how to procure 
additional transportation. 

5. Schools - There are no separate plans or procedures for each school and 
day care center. Bus companies and drivers have not signed agreements 
to perform during an evacuation. The school plan lacks detailed pro- 
cedures. Estimated time to mobilize National Guard for schools is three 
hours, and Guardsmen may not be familiar with road network. 

RECOMMENDATIONS: 

1. Conduct a survey to determine transportation needs of all people 
dependent on public transportation in all sectors of EPZ. Provide 
specific and separate information for summer/non-summer, weekday/weekend 
populations . 

2. Document available resources and resource needs, such as transportation 
contractors, trained personnel, drivers trained in emergency response 
procedures, special care personnel and equipment for disabled persons. 

3. Obtain written agreements with transportation contractors and drivers. 

A. Develop specific, adequate plans to evacuate each dependent group, such 
as the population in nursing homes, hospitals, schools, camps, 
residential homes, correctional institutions, day care centers. 

5. Provide for special needs population - physically and mentally 
handicapped people: 

a. Provide notification in advance of special evacuation procedures 
for disabled people; 

b. Plan for delivery of necessary services during an emergency with 
trained assistance for each handicapped person designated 
beforehand ; 

c. Provide beepers, backup personnel for vacation times, special 
equipment and medications. 

7 



67 



F. RECEPTION CENTERS AND SHELTERS 
Bridgewater State College and Taunton State Hospital 
DEFICIENCIES: 

1. There are no clearly defined functions for the reception centers and 
shelters . 

2. There are no letters of agreement, or contracts with reception centers. 
(Who provides what and who pays?) 

3. There are no adequate plans, equipment, supplies or personnel to 
implement purposes for reception centers. (Such as contamination 
monitering, decontamination, congregate care, ...) 

4. Public shelter locations are not identified. 

5. Adequate plans for public shelters are non-existent (personnel, 
supplies, etc.) 

6. Resettlement and/or reentry plans have not been formulated. 

7. The option of sheltering in private homes versus evacuation is not 
addressed . 

RECOMMENDATIONS : 

1. Define specific and separate functions for public shelters and reception 
centers . 

2. Specify conditions for which sheltering in private homes might be 
preferable to evacuation. 

3. Conduct survey of potential shelters adequate to accommodate peak summer 
populations . 

4. Identify and contract for an adequate number of reception centers and 
public shelters to accommodate EPZ population. 

5. Provide adequate plans for equipment, supplies and personnel for centers 
and shelters. 



68 



G. MEDICAL FACILITIES 
DEFICIENCIES: 

1. There are inadequate plans for treating large numbers of victims of 
radiation exposure. 

2. The two hospitals listed in the Flan (Jordan and St. Luke's) can treat 
only a limited number of people with radioactive contamination. 

3. One hospital is within the EPZ and could be simultaneously receiving and 
evacuating patients. 

RECOMMENDATIONS : 

1. Clearly determine response capacity of Jordan and St. Luke's Hospitals. 

2. Identify all possible referral hospitals outside EFZ. 

3. Document capacity, types of care and provisions available at referral 
hospitals outside EFZ. 

4. Obtain signed agreements with referral hospitals. 

5. Develop procedures for transportation of patients outside the EPZ. 

H. RADIOFROTECTIVE DRUGS 

PRESENT POLICY: 

The Massachusetts Department of Public Health does not advise distribu- 
tion to the general public of Potassium Iodide (KI) as a radioprotective 
drug. 

RECOMMENDATION: 

That the Department of Public Health provide for the distribution of 
Potassium Iodide or a proven alternative to the general Plymouth population 
prior to reactor start-up. 



In conclusion, the Committee notes, once again, that the deficiencies 
identified herein and the recommendations made relative to the Plymouth RERP 
are by no means exhaustive or all-inclusive. Those listed are, however, 
serious enough that, were they not to be addressed, the selectmen might be 
unable to "... provide for the health and safety of persons and their 
property ..." during a radiological emergency. Hence, the Committee respect- 
fully urges the Selectmen to give immediate attention to the matters con- 
tained in this report. Even after the current revision of the RERP and the 
implementation of recommendations, regular monitoring by the Town will be 
needed so that improvements in the plan may be made as they become necessary. 



69 



TOWN OF PLYMOUTH 
COMMITTEE ON NUCLEAR MATTERS 



COMMITTEE REPORT 



ENVIRONMENTAL RADIATION MONITORING 
PILGRIM NUCLEAR POWER STATION 



December 1987 



70 



COMMITTEE MEMBERS: 



Grace M. Healy, Chair 
Charles W. Adey, Vice-Chair 
Ann Waitkus Arnold 
Theodore L. Bosen 
Marie P. Fehlow 
Kathleen M. Leslie 
Anthony V. Lonardo 
John P. Rooney 
Howard E. Shetterly 



SUBCOMMITTEE MEMBERS: 



Kathleen M. Leslie, M.D. 
Marie P. Fehlow, R.N, 



The Connnittee thanks Mrs. Pauline M. Howe for her invaluable 
assistance in editing and typing this Report. 



71 



REPORT ON 

PILGRIM NUCLEAR POWER STATION 

ENVIRONMENTAL RADIATION MONITORING 



OVERVIEW 

The Committee on Nuclear Matters, in an attempt to understand the monitoring 
of environmental radiation associated with the Pilgrim Nuclear Power Station, 
reviewed documents provided by Boston Edison and interviewed knowledgeable 
persons, including but not limited to Boston Edison representatives, Nuclear 
Industry representatives, Department of Public Health representatives and 
State Officials. 

The Committee on Nuclear Matters is strongly concerned with what it considers 
to be the insufficient number of monitoring stations, the minimal involvement 
of the State in the monitoring process, and the complete lack of an 
"oversight" monitoring system. 

The Committee respectfully urges the Selectmen to consider well these 
recommendations and to request both Boston Edison Company and the 
Commonwealth of Massachusetts to act expeditiously on these recommendations, 
which the Committee considers to be basic and modest. 



INTRODUCTION 

This document contains Committee recommendations, with a sampling of the 
pertinent materials reviewed. The latter are intended to provide some 
background for the recommendations made herein. 

There are two sections in this document: 

Section I: Summary, Conclusions and Recommendations 

Section II: Background Materials 

* Excerpts from PNPS-1 Environmental Monitoring Program Reports 
Numbers 15, 17, 18. 

* Excerpts from PNPS-1 Environmental Monitoring Program Report 
Number 19 and Radioactive Effluent and Waste Disposal Report 
January - June 1987. 

* Department of Public Health Monitoring Program. 

* Glossary 



It should be noted that Section II is only an outline of "Findings." The 
reader is referred to the complete Boston Edison Program Reports, which are 
available at the Plymouth Public Library. 



72 



SECTION I 
SUMMARY, CONCLUSIONS AND RECOMMENDATIONS 

RADIATION MONITORING AMD THE PILGRIM NUCLEAR POWER STATION 

SUMMARY 

1) The presence of Pilgrim Nuclear Power Station (PNPS)-related isotopes 
has been documented offsite in shellfish, ocean fish, algae, ocean floor 
sediment, and garden produce. In addition, PNPS-related isotopes are 
present in water samples from the discharge canal, and a single isotope, 
H-3 (Tritium), has been found in a nearby pond. Onsite locations that 
monitor for airborne radiation are positive for Co-60 (Cobalt).* 

2) Environmental radiation monitoring: 

a) Airborne radiation is measured weekly for beta particles, 
quarterly for gamma radiation. 

b) Thermoluminescent Dosimeters (TLDs), which monitor gamma radiation, 
are analyzed quarterly . 

c) Liquid effluent from the plant's discharge canal is analyzed weekly 
by Boston Edison and monitored weekly by the Department of Health 
(DPH). 

d) Stack monitors which record gaseous, particulate, and Iodine 
(1-131) releases from PNPS are reviewed weekly by the DPH and 
analyzed weekly by Boston Edison. 

3) Monitoring data are made available to the public in the local library 
six months after the year ends. ( Environmental Radiation Monitoring 
Program Report .) 

4) The NRC has faulted Boston Edison's TLD program in the SALP Report for 
November 1, 1985 through January 31, 1987: 

"... problems were identified in the licensee's environmental 
thermoluminescent dosimeter (TLD) program. Commitments made by the 
licensee during previous assessment periods to improve the 
environmental TLD program were not implemented. Because of these 
problems, the validity of the environmental TLD data cannot be 
assured. This indicated lack of management involvement in this 
area and a lack of understanding and thoroughness with regard to 
resolution of technical issues." 

5) Monitoring of residential areas contiguous to the plant is virtually 
non-existent. 

6) The DPH, NRC, and Boston Edison do not react quickly enough and strongly 
enough, with additional monitoring — particularly offsite, when there 
are unplanned radiation releases. 

* Throughout this report, symbols such as Co , are written as Co-60. 

This representation is used extensively in Boston Edison and State reports 
and in non-technical informational materials. 



73 



CONCLUSIONS 



All of the Reports reviewed by the Committee on Nuclear Matters (1982-1987) 
indicate to its members that the Pilgrim Nuclear Power Plant does have a 
continuing environmental impact. In all of the materials reviewed, however, 
Boston Edison Company, the N.R.C., and the Commonwealth hold that offsite 
releases from the Plant (as indicated by current monitoring) have not 
exceeded technical specifications. Boston Edison Company, the N.R.C., and 
the Commonwealth then draw the conclusion that there has been no measurable 
impact upon the citizenry. They further claim that even if there had been 
any impact it would have been minimal, and far less than the effects of 
previous worldwide weapons testing or of the Chernobyl accident. 

The Committee on Nuclear Matters takes little comfort in the above 
comparisons. Any environmental impact is of concern and needs to be examined 
if public health is to be protected. The Committee questions the adequacy of 
current monitoring around Pilgrim I, even though it may be more extensive 
than that at some other nuclear plants. Hence, the Committee recommends 
increased monitoring, higher quality monitoring, proper timing of monitoring 
to reveal effects of specific plant incidences which involve radioactive 
releases, and prompt reporting of the results. Accomplishment of these 
recommendations is basic to an investigation of the impact of PNPS upon 
citizens' health. 



74 



RECOMMENDATIONS 



1. The Commonwealth of Massachusetts should establish a comprehensive, 
state-of-the-art radioactive monitoring system, the purpose of which is 
to measure instantaneously the type and quantity of radioactive 
emissions and effluents at each release point of nuclear reactors. The 
intent of the Committee in this recommendation is the establishment of 
an independent monitoring (oversight) system which will go far beyond 
the minimum monitoring now done by the Department of Public Health. 

2. Such a system will require substantial resources. To that end, the 
owners of nuclear power plants within the Commonwealth of Massachusetts 
should be assessed the costs of establishing and operating the 
comprehensive, state-of-the-art monitoring system. 

3. Since an extended time period will be involved in bringing this 
comprehensive monitoring system on line, the following immediate 
response is recommended: 

As an interim measure, the committee recommends that a qualified state 
team should be established as soon as possible to monitor plant 
activities relative to radiological releases which affect the well-being 
of the citizenry. This team will be located onsite and report to 
appropriate State decision makers. This will not be a continuing 
arrangement, but merely a first step toward the permanent system 
specified in recommendation number 1. 

4. Boston Edison should increase its air particulate, gaseous radioiodine 
and soil surveillance stations. These additional stations should be 
adequate to ensure that no substantial radioactive material can be 
released without detection. 

5. Boston Edison should install additional TLD's around the Plant to ensure 
reliable quantification of total offsite dose rate. 

6. Boston Edison should increase the numbers of samples collected and the 
locations and frequency of collection of shellfish. 

7. Boston Edison should improve quality control with respect to its 
radiation monitoring so that equipment failure is immediately 
recognized. 



75 



SECTION II 
BACKGROUND MATERIALS 



PILGRIM NUCLEAR POWER STATION 
ENVIRONMENTAL RADIATION MONITORING PROGRAM 

Excerpts from REPORT NO. 18 (1985), REPORT NO. 17 (1984) and REPORT NO. 15 
(1982). 

ENVIRONMENTAL RADIATION 

A. AIRBORNE 

Airborne radiation is monitored at the locations listed by Boston Edison 
in table 4.8.2. of Report #18. (See the following page.) Particulates, 
radioiodine, and soil are sampled. The collection system consists of a 
cellulose particulate filter and a charcoal filter cartridge which are 
used to collect particulate matter and iodine nuclides respectively. 
Analyses of the particulate filters for beta radiation is performed 
weekly. 1-131 analyses are performed weekly as well. In addition 
quarterly composite particulate samples are tested for gamma emitting 
nuclides. Soil analyses are performed once per three years for gamma 
isotopes. 

FINDING 

Cobalt (Co-60), attributed to operation of PNPS, has been found at 
onsite locations including the overlook, pedestrian bridge, and 
warehouse. It has been identified in the soil at the pedestrian bridge. 

B. DIRECT 

Dosimeters, located at twenty areas (as listed in table 4.8.3) are 
analyzed on a quarterly basis for gamma radiation. 

FINDING 

According to Boston Edison, "beyond the 'exclusion area' (for this 
purpose, the, 0.25-0.7 mile region), dose rates show no significant plant 
effect " 



Environmental Radiation Monitoring Program, Report No. 18 (1985), 
pp. 3-16, 3-17. 



76 



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77 



C. WATERBORNE 

Waterborne radiation is monitored at the plant's discharge canal, at 
Bartlett Pond (which is 1.7 miles SE of the plant) and at Powder Point 
Bridge (which is 7.8 miles NNW of the plant). Discharge canal samples 
are collected every one-half hour; weekly "grab samples" are taken from 
the Bartlett Pond and from Powder Point Bridge seawater. Analysis is 
monthly for gamma isotopes and quarterly for H-3 . 

FINDING 

Cesium (Cs-137), Cobalt (Co-60), and Tritium (H-3) have been present in 
discharge canal samples. H-3 has been found at Bartlett Pond. These 
isotopes, according to Boston Edison, are attributed to operation of 
PNPS. 

D. AQUATIC 

Aquatic samples include shellfish, Irish moss (algae), lobster, fish and 
ocean floor sediments. 

1. Shellfish 

Shellfish samples are analyzed quarterly for gamma isotopes. 
Locations sampled are discharge outfall, Duxbury Bay, Manomet 
Point, Plymouth or Kingston Harbor, and Marshfield. 

FINDING 

Samples from the discharge canal have been positive for Mn-54, 
Zn-65, Co-60, Co-58, and C8-137. Samples from Manomet Point have 
been positive for Mn-54, Co-60, Cs-137, Zn-65. Testing for Co-60, 
Cs-137 has been positive in Warren Cove samples. According to 
Boston Edison, all of these isotopes are attributable to operation 
of PNPS. 

2. Algae 

Algae samples are collected quarterly from the discharge canal, 
Manomet Point, and Ellisville. 

FINDING 

Samples from the discharge canal have demonstrated Zn-65, Cs-137, 
Mn-54, Co-58 and Co-60. Algae from Manomet Point have demonstrated 
Mn-54 and Co-60. Ellisville has been positive for Mn-54 and Co-60. 
According to Boston Edison, all of these isotopes are attributable 
to operation of PNPS. 

3. Lobster 

Lobster is collected four times per season in the vicinity of 
discharge point and annually offshore. It is analyzed for gamma 
isotopes. 

FINDING 

No plant attributable isotopes were found. 

7 




78 



4. Fish 

Gamma isotopic analyses are performed from four separate fish 
groups: bottom oriented, near bottom, anadromous, and coastal 
migratory. They are caught in the vicinity of the discharge canal 
as well as at a control point at a distance offshore. Analysis is 
quarterly for bottom and near bottom fish, in season for anadromous 
and coastal migratory. A control analysis from fish caught 
offshore is performed annually. 

FINDING 

j Bluefish and cod samples from the discharge canal have been 
/ positive for Cs-137. A salmon sample from the mouth of the North 
/ River in Hanover was positive for Cs-137. This isotope was 
< attributed by Boston Edison as being due to radioactive releases 
— from PNPS. 

5. Sediments 

Sediment samples are taken semi-annually at Rocky Point, Warren 
Cove, Plymouth Harbor, Duxbury Bay, Plymouth Beach, Manomet Point, 
and a control point in Marshfield. 

FINDING 

Analyses performed at Duxbury Bay, Plymouth Beach, Warren Cove, 
and Marshfield demonstrated Cs-137. This is attributed "....to 
some extent..." to the fission products related to fallout from 
previous weapons testing. Rocky Point, Manomet Point, Duxbury Bay 
have had positive values for Co-60 which Boston Edison attributes 
to operation of PNPS. 

E. TERRESTRIAL 

Terrestrial samples include milk, cranberries, vegetables, and beef 
forage or cattle feed. 

1. Milk 

Milk is collected from the cows at the Plymouth County Farm and 
Whitman Farm, semi-monthly when the animals are on pasture, 
otherwise at a monthly interval. Analyses for gamma isotopes, 
Sr-87, Sr-90, and 1-131 are performed. 

FINDING 

The 1982 Report states that of the isotopes present, i.e., Sr-90, 
Sr-89, Cs-137, ",..PNPS-1 probably contributed much less than 0.01% 
of the measured concentration..." Most is attributed by Boston 
Edison to fallout from nuclear weapons testing. 



Environmental Radiation Monitoring Program, Report No. 17 (198A), 
p. 3-47. 

8 



79 



2. Cranberries 

Cranberries from a Manomet Point Bog (2.6 miles SE), Bartlett Road 
Bog (2.8 miles SSE/S), and Pine Street Bog (17 miles WNW) are 
analyzed for gamma isotopes at the time of harvest. 

FINDING 

Cs-137 has been found at the Manomet Point Bog at a level 
greater than ten times average background for that isotope. A 
comprehensive study of cesium uptake in cranberries was performed 
during 1978. This report identified fallout from previous nuclear 
weapons testing as the primary source of cesium in cranberries. 

3. Vegetables 

Vegetable samples are collected at the Karbott Farm and Bridgewater 
Farm as well as other nearby gardens. 

FINDING 

Co-60 at farms 1.5 miles SSW and 1.0 miles W were attributed to 
controlled releases from PNPS. In addition, Cs-137 present in the 
sample at the farm 1.5 miles SSW was attributed to PNPS. 

4. Beef Forage 

Beef forage is tested annually from the Plymouth County Farm, 
Whitman Farm, and Bridgewater Farm. 

FINDING i 

No plant related isotopes have been found. 



It might be of interest to the reader to note the selected gamma exposure 
data from the 1982 Report which are found on the following pages. If one 
compares gamma exposure across each of the quarters at each station listed, 
one can clearly see some patterns of increased exposure. There are, however, 
inconsistencies between the distance of some stations from the Plant and the 
level of reading obtained during a given quarter. 

Such inconsistency needs to be addressed by Boston Edison and by the 
Commonwealth. At the least, there should be an increase in the numbers of 
TLD's, particularly in areas contiguous to the Plant. Stations should form 
a tight ring around the plant and rings should be replicated, as far as 
feasible, in circles of widening radii. 



Environmental Radiation Monitoring Program, Report No. 15 (1982), 
p. 3-69. 



80 



GAMMA EXPOSURE (TLD) SELECTED DATA FOR FOUR QUARTERS OF 1982 



Distance and Microrads per Hour 

Station Location Direction . Quarter of 1982: 

( Designation ) from Reactor First Second Third Fourth 



OFFSITE STATIONS : 

East Weymouth (EW) * 23 miles NW 

Kingston (KS) 10 Miles WNW 

Sagamore (CS) 10 miles SSE-S 

Plymouth Airport (SA) 8 miles WSW 

North Plymouth (NP) 5.5 miles WNW 

Plymouth Center (PC) 4.5 miles W-WNW 

South Plymouth (SP) 3 miles WSW 

r- 1^ Manomet (MS) 2.5 miles SSE 

.^ Manomet (ME) 2.5 miles SE 

-- Manomet (MP) 2.25 miles ESE-S 

^ Cleft Rock Area (CR) 0.9 miles S 

* Control Station. 

ND No Data due to missing TLD. 

Continued 
10 



4.00 


8.30 


11.84 


8.62 74c_,^ 


4.41 


6.45 


8.14 


8.55 ^-^v, 


5.22 


ND 


6.82 


6.50 ^G^j-u 


2.68 


5.89 


15.40 


6.87 ^^(^.^ 


4.59 


8.47 


14.11 


8.21 -iU.,^ 


ND 


4.60 


7.62 


6.01 y'llo^^^ 


5.91 


6.80 


12.91 


6.61 °i ^^J 


4.73 


8.28 


20.77 


9.28 <5U.^^ 


6.46 


9.33 


16.43 


HD Vl«^ 


5.11 


7.19 


10.91 


7-59 Hv,,^ 


7.97 


8.89 


15.52 


8.57 -/^o^ 



81 



GAMMA EXPOSURE (TLD) SELECTED DATA FOR FOUR QUARTERS OF 1982 

Distance and Microrads per Hour 

Station Location Direction Quarter of 1982: 

( Designation ) from Reactor First Second Third Fourth 



ONSITE STATIONS 

Rocky Hill Road (ER) 0.8 miles SE 

Microwave Tower (MT) 0.38 miles S 

Rocky Hill Road (WR) 0.3 miles W-WNW 

Rocky Hill Road (B) 0.26 miles SSE 

Property Line (H) 0.21 miles SSW 

Property Line (I) O.IA miles W 

Public Park. Area(PA) 0.07 miles N-NNE 

Overlook Area (OA) 0.03 miles W 

Property Line (PL) 0.34 miles NW 

Ped. Bridge (PB) 0.14 miles N 

East Breakwater (EB) 0.35 miles ESE 

Warehouse (WS) 0.03 miles SSE 



4.63 


6.14 


6,91 


10.84 


^^/^c^ 


4.06 


9.55 


13.21 


9.44 


A.J 


4.64 


11.22 


17.15 


9.85 


4.02 


8.94 


8.28 


11.15 


k<Uo^ 


8.11 


15.97 


11.43 


12.89 


4.34 


8.98 


10.93 


9.31 




5.07 


8.73 


11.26 


7.30 


lyeio K^ 


6.95 


22.51 


30.99 


22.97 


^J^-" i-'t^ 


4.38 


7.29 


11.75 


10.31 


^-^ 


8.32 


17.49 


22.81 


17.60 


^^^ 


4.84 


8.18 


10.10 


7.77 


6.38 


10.83 


26.60 


14.03 


q.i^-s 



Geographic Regional Averages: 

Near Plant - 0.16 miles 09.18 14.89 22.92 15.47 

Exclusion Area 0.25 - 0.68 miles 5.54 9.10 11.22 9.56 

Distant Neighborhood 0.7 - 6.5 miles 4.39 8.03 11.74 7.86 

Background 8-21 miles 4.08 6.87 10.55 7.63 

* Control Station. 

ND No Data due to missing TLD. 

11 



82 



PILGRIM NUCLEAR POWER STATION 

ENVIRONMENTAL RADIATION MONITORING PROGRAM 

Report Number 19 

January 1 - December 31, 1986 

The following information was excerpted from the above mentioned report when 
it became available from Boston Edison Company. Only "Findings" are included 
herein since explanations of data collection locations and methods were 
described earlier. 

RESULTS OF ANALYSES 

A. AIR PARTICULATE FILTERS 

FINDING 

There were no positive measurements of any nuclides characteristic of 
reactor operations attributable to PNPS-1 observed in the quarterly 
composite samples. There were positive measurements of nuclides 
characteristic of reactor operations attributable to the Chernobyl 
Nuclear Power Plant accident in the second quarter composite samples. 
These nuclides were: Ru-103, Cs-134 and Cs-137. In addition, high 
concentrations of Be-7 were also seen. 

B. IODINE 

FINDING 

As a result of the Chernobyl accident, positive indications of 1-131 
were detected in the charcoal filters in all stations from week #20 
through week #24 (late May to early June) with the highest 
concentrations seen during week #21. 

C. SOIL 

FINDING 

Soil analyses are performed once every three years for gamma isotopes. 
See 1982 report. 

D. DIRECT RADIATION 

1. CONTINUOUS TLD 

FINDING 

Beyond the "exclusion area" (for this purpose, the 0.25-0.7 mile 
region), dose rates show no significant plant effects. 

2. FIELD SURVEY 

FINDING 

Survey results are within the expected natural background exposure 
rates in the northeastern part of the United States. 

12 



83 



E . WATERBORNE 

FINDING 

There were no positive measurements of nuclides characteristic of 
reactor operation observed at any of the three sampling locations. The 
only positive measurements observed were due to naturally occurring 
nuclides (K-40 and AcTh-228). 

F. SHELLFISH 

FINDING 

There have been positive measurements of Be-7, Mn-54, Co-60, AcTh-228 
and K-AO in samples from the Discharge Canal. In addition, there have 
been positive measurements of Be-7, AcTh-228 (peak) and K40 at Warren 
Cove; AcTh-228 and K-40 at Duxbury Bay; and Be-7, AcTh-228 and K-40 at 
the control station in Marshfield. Tl\|gj;:£_vrasone positiv e measu rement 
of Ru-103 at Manomet Point in a sample which was collected on 7/8/86. 



The observed concentrations of Mn-54 and Co-60 were the result of PNPS-1 
liquid releases. "Qie co ntribution of Ru-103 was due to Cherno byl- 
r elated radioactivi ty^ The observed concentrations of Be-7, AcTh-228 
and K-40 are due to the natural occurrence of these nuclides. 

G. ALGAE (IRISH MOSS) 

FINDING 

There have been positive measurements of Be-7, Co-60, Ru-103 and K-40 at 
the Discharge Canal. In addition, there have been positive measurements 
of Be-7, Co-60, Ru-103, 1-131, AcTh-228 and K-40 at Manomet Point 
(Station 15-3 miles-SE); and Be-7, Co-60, AcTh-228 and K-40 at the 
control station at Ellisville (Station 22-8 mi-SSE). 

The measured concentrations of Co-60 at the Discharge Canal are 
certainly due to liquid effluents from PNPS-1. The observed 
concentrations of Co-60 at Manomet Point and Ellisville were the result 
of PNPS-1 liquid releases. The highest concentration of Co-60 was seen 
at the Discharge Canal. 

H. LOBSTER 

FINDING 

The results are unremarkable in that there were no positive measurements 
of any isotopes other than K-40 in either the indicator or the control 
samples (K-40 is a naturally occurring nuclide). 



13 



84 



I. FISH 

FINDING 

A striped bass sample collected on 10/2/86 at the Discharge Canal 
Outfall Area indicated a positive measurement of Cs-137. 

J. SEDIMENTS 

FINDING 

It is clear that positive measurements of Co-60 and Cs-137 were 
observed. The highest concentration of Co-60 was observed in a sediment 
sample (24-26 cm) taken from Rocky Point (Station 11) on 5/19/86. In 
addition, Co-60 was observed in all of the sediment segments (0-30 cm) 
obtained from Rocky Point on 5/19/86 and in two sediment segments (16-20 
cm) from Duxbury Bay collected on 5/29/86. The concentrations of Co-60 
at Rocky Point are due to liquid .affluents from PNPS-1 . The 
concentration of Cs-137 at the 24-26 cm level from Rocky Point was most 
likely due to controlled liquid releases from PNPS-1. The measured 
concentration of Be-7 , and to some extent Cs-137, at Duxbury Bay, 
Plymouth Harbor and Marshfield are attributable to the fission products 
related to fallout from previous weapons testing. , 

K. MILK 

FINDING 

The positive measurements of 1-131 in the samples from week #19 through 
week #27 (late May until early July), and the positive measurements of 
Cs-134 and Cs-137 from week #21 through week #27 were attributable to 
Chernobyl-related radioactivity. There was only a small amount of 
strontium released during the Chernobyl accident which resulted in 
negligible Sr-89 and Sr-90 in the Chernobyl-related radioactivity. 

The highest concentration of Sr-90 occurred at Plymouth County Farm 
(collected on 9/4/86) and the highest concentration of Sr-89 occurred at 
the Plymouth County Farm (collected on 6/19/86). However, there were no 
positive measurements made of either Sr-89 or Sr-90, there were only 
indications of the presence of Sr-90. It is unlikely that PNPS-1 is the 
major source of the indicator station activity. 

Prior to week #21 and after week #27, the highest concentration of 
Cs-137 occurred at Plymouth County Farm (3.5 mi-W) in early September 
(Collected on 9/4/86). Edison claimed that the primary source of Cs-137 
was other than PNPS-1, and was most likely due to fallout from previous 
atmospheric weapons testing. 



14 



85 



L. CRANBERRIES 

FINDING 

The only manmade radionuclide detected was Cs-137, which appeared in the 
Manomet Point Bog sample (collected on 9/23/86). Claim was again made 
that the measured concentration was due to fallout from previous weapons 
testing and a lack of adequate potassium in the soil. 

M. VEGETATION 

FINDING 

The only nuclides observed, other than naturally occurring Be-7, 
AcTh-228 (peak) and K-40, was Cs-137. A positive measurement of Cs-137 
was detected in vegetation collected from two locations on 9/16/86. 
Because of the absence of Cs-134 Edison again concluded that weapons 
testing fallout was the primary source of Cs-137. 

N. FORAGE 

FINDING 

The following positive measurements were detected at two stations: Be-7, 
Ru-103, Cs-134, Cs-137 and K-40. The beef forage samples were both 
collected on 6/19/86. Edison again concluded that the contribution of 
Ru-103, Cs-134, and Cs-137 were due to the Chernobyl accident. 



In addition to the above data from the 1986 Report, some data from the 
Radioactive Effluent and Waste Report (January - June 1987) can be found on 
the following page. These data are of interest in that they demonstrate 
continued releases of materials into Cape Cod Bay during periods of Plant 
shut-down. Plant decontamination accounts for increased numbers of batch 
releases. (The decrease in average stream flow in number 6 was due to the 
use of one pump rather than three.) 



15 



86 



SOURCES OF DATA : 



PILGRIM NUCLEAR POWER STATION 
ENVIRONMENTAL RADIATION MONITORING PROGRAM 
REPORT NUMBER 19 
January 1 - December 31, 1986 



AND 



RADIOACTIVE EFFLUENT AND WASTE DISPOSAL REPORT 
January 1 - June 30, 1987 



BATCH RELEASES OF RADIOACTIVE MATERIALS IN LIQUID EFFLUENTS 

INTO CAPE COD BAY 

January July to January 

to June December to June 

1986 1986 1987 



1. Number of batch releases 143 



125 211 



2. Total time period for 

batch releases (Hours) 368.7 216.7 439.7 

3. Max-i'mum time period for 

a batch release (Hours) 8.42 10,4 16.2 

4. Average time period for 

batch releases (Hours) 2.57 1.7 2.0 

5. Minimum time period for 

a batch release (Hours) 0.25 0.08 0.25 

6. Average stream flow during periods 
of release of effluent into a 
flowing stream (Gallons per 

""■""'^^ 234,500 155,000 79,200 



16 



87 



DEPARTMENT OF PUBLIC HEALTH RADIATION MONITORING PROGRAM 

This report is based upon data supplied to Dr. Kathleen Leslie and Ms. Marie 
Fehlow by Robert M. Hallisey, Director, Radiation Control Program, 
Massachusetts Department of Public Health (DPH). 

The DPH monitors radiation emissions from PNPS via three routes: 

(1) thermoluminescent dosimeters (TLDs), (2) main stack and reactor building 

vent monitors, and (3) discharge canal releases recording equipment. 

A. TLDs 

DPH TLDs have been in place since the third quarter of 1981. They are 
located at twenty-four sites within a five-mile radius of the plant. 
TLDs measure gamma radiation and are read quarterly. Some State TLDs 
are located together with those of Boston Edison and the NRC , some are 
located separately. According to Mr. Hallisey, monitoring is necessary 
only within the five-mile radius because, should increases in radiation 
levels be demonstrated close to the Plant, "doses at further distances 
can be calculated using the inverse square law." 

FINDING 

The State has not found any levels of radiation that exceed background 
at their TLD stations. 

B. Stack Emissions 

The DPH visits PNPS weekly to inspect the automatic strip chart recorder 
from the main stack and the reactor building vent for quantitative 
release rates from each stack of gaseous effluents, particulates, and 
1-131. 

FINDING 

Inspection of reports from 1/86 - 10/86 revealed no gaseous releases 
which exceeded technical specifications. 

C. Liquid Releases 

The DPH visits PNPS weekly to inspect the recording of liquid releases 
from PNPS into the ocean. 

FINDING 

Inspection of reports from 1/86 - 10/86 revealed no releases of liquid 
effluents which exceeded technical specifications. 



17 



88 



GLOSSARY 

1) Radiation - Radiation is energy in the form of waves or particles that 
can penetrate matter. Although the term "radiation" includes such 
things as light or radio waves, it is most often used to mean "ionizing" 
radiation, which can produce charged particles ("ions") in materials it 
strikes . 

2) Ionizing radiation - Has the ability to knock electrons out of atoms, 
creating electrically charged ions. These ionized atoms have the 
ability to damage living tissue. Examples: x-rays, gamma rays, alpha 
particles . 

3) Nonionizing radiation - Does not have the above property. Examples: 
microwaves, sound waves, light. 

4) Radioactivity - Results from the release of radiation from the nucleus 
of an atom with an unstable ratio of protons to neutrons in order to 
achieve stability. 

5) Particulates - Microscopic particles that may be radioactive. 

6) Noble gas - A gas that is chemically and biologically nonreactive, e.g., 
xenon and krypton. 

7) Alpha radiation - Consists of positively charged particles. Alpha 
radiation will be stopped by the outer layer of skin; it can be stopped 
completely by a sheet of paper. However, the potential hazard from 
alpha emitting materials is due to the possibility of internal 
deposition to the body by ingestion or inhalation. 

8) Beta radiation - Beta particles are similar to electrons, but originate 
in the nucleus of the atom. Beta is more penetrating than alpha 
radiation and can pass through 0.5-1 centimeter of water or human flesh. 
A sheet of aluminum a few millimeters thick can stop beta radiation. 
There is also an inhalation hazard from beta radiation. 

9) Gamma radiation - Consists of photons (wave energy) that can be very 
penetrating. Depending on the energy levels, gamma radiation can pass 
through the body. Dense materials such as concrete and lead are used 
for shielding against gamma radiation. 

10) Effluent (radiological) - Release of radionuclides originating from the 
reactor vessel into the environment. 

11) Manmade radiation - Radiation from medical and dental use of X-rays and 
radioactive materials to diagnose and treat disease, giving an average 
dose of 90 mr/year/person. Another 10 mr/year/person are received from 
fallout from nuclear weapons testing, nuclear power plants, industrial 
uses of radioactive materials and minute emissions from certain consumer 
products such as color television sets. 

Continued 
18 



89 



GLOSSARY (Continued) 

12) Natural background radiation - Radiation from natural sources such as 
cosmic rays, granite, natural gas; an average of 100 millirems/year/ 
person. 

13) Rad - Radiation absorbed dose or amount of energy deposited in living 
tissue by ionizing radiation. 

14) Rem - A unit for measuring the biological effects on a person from a 
dose of radiation. A rem of exposure produces a constant biologic 
effect regardless of the type of radiation. 

15) Millirem - 1/1000 of a rem. 



19 



90 

The Chairman. Thank you, Dr. Healy. I think we'll hear more 
about some of these issues when we hear from some of our State 
officials and the relationship between their authority and the 
power of the Federal Regulatory Commission, and I look forward to 
that. 

Let me ask you. Dr. Healy. You're familiar with Dr. Cobbs' 
report about the increased leukemia rates that he discovered? 

Dr. Healy. Yes. 

The Chairman. And we'll make that report a part of the record. 
Rather than my reading through that, perhaps you could briefly 
describe the conclusions. 

Dr. Healy. Well, what Dr. Cobbs did is he made note of the 
highly unusual incidents of leukemia in a five-town range, which 
includes: Plymouth, Kingston, Duxbury, Marshfield, and Scituate 
and what he attempted to do was to connect this incident with ra- 
dioactive emissions from the plant. 

What he — my understanding is what he hypothesized was that 
the topography, the coastal wind circulation and the coastal fogs 
formed a natural barrier, which would hold and entrap radioactive 
residues from Pilgrim I. 

Our committee is aware that there is some disagreement with 
the topography-wind hypothesis, but we are checking into it with 
our experts, but quite frankly, Mr. Chairman, our committee is not 
so much interested in such theories. We are far more interested in 
the data that we can get from the field, and those data, and only 
those data, we feel from the monitoring, are going to allow us to 
get to any causal inferences, and we strongly recommend 

The Chairman. Now, the State has looked into this as well, has 
it not? 

Dr. Healy. The State has used data from — my understanding is 
that the State has analyzed and reanalyzed data from the Cancer 
Registry, but those data our committee feels are flawed in that the 
procedures and the methodology are flawed. It is my understanding 
that they are moving toward a comprehensive study at this time, 
but our committee will be recommending that we go far beyond the 
State to the national level. 

The Chairman. I think the suggestions which you make, and 
which Mary Ott and others have made with regard to health stud- 
ies are excellent suggestions, as we have heard in your testimony, 
and read about in preparation for the hearing, and also in some of 
the communications that we have received from many of you and 
from others. It seems that the kind of pattern that we have heard 
here is very similar to the type of pattern that we heard about in 
connection with Three Mile Island in 1979 when this committee 
held hearings on the health implications of that particular difficul- 
ty. 

So I have written a letter to the National Institutes of Health, to 
Dr. Wyngaarden, who is the Director of the NIH, and asked him to 
do a health study. My request for investigation refers to, and I 
quote, "reports of excessive leukemia in certain Massachusetts 
towns downwind from the Pilgrim I power plant in Plymouth"; and 
I have specifically asked him to have his people determine whether 
there is a causal connection. I have also told him the he might 



91 



want to take a look at the problems at Three Mile Island as well. I 
have sent that out today. 

I will be in touch personally with Dr. Wyngaarden, and as soon 
as I get some results or some response, I will share it with you and 
other members of the community. 

[The information referred to follows:] 



92 



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Bnited States ^tnatc 

COMMITTEE ON LABOR AND 
HUMAN RESOURCES 

WASHINGTON DC 20510-6300 



January 7, 1987 



Dr. James B. Wyngaarden, Director 
National Institutes of Health 
14 North Drive 
Bethesda, Maryland 20814 

Dear Dr. Wyngaarden: 

Over the past year, a number of individuals and groups have 
urged the Committee to hold hearings on the subject of adverse health 
effects of radiation exposure. They are obviously concerned about 
those dangers in the context of potential nuclear power plant 
accidents. They are also concerned about those dangers as a 
result of the possibility of low-level radiation emanating from 
such plants. And, of course, considerable alarm has been 
expressed with respect to this subject as it relates to the 
accident which occurred at the Three Mile Island (TMI) plant. 

It has been my view that hearings may be appropriate at- 
such time as there are adequate data available, and when 
appropriate scientific inquiries have been conducted. At that 
time, a comprehensive public airing of the relevant information, 
and consideration of proposals for remedial action could be useful 
and productive. 



In view o 
prompted legit 
relating to th 
Institutes of 
into this enti 
taking address 
been a causal 
excesses of ca 
similar report 
towns "downwln 
Massachusetts , 
that situation 



f the number of incidents and situations which have 
imate concern, and because of the dearth of data 
is subject, it would be helpful for the National 
Health (NIH) to conduct an appropriate inquiry 
re question. I would urge that such an under- 

the question of whether the TMI accident has 
factor in what has been described as "observed 
ncer." In addition, because there have been 
s of excesses of leukemia in certain Massachusetts 
d" from the Pilgrim I power plant in Plymouth, 

it would be helpful to have your assessment of 

as well. 



I am sure you are familiar with the studies which have 
already been carried out with respect to increased cancer rates 
near nuclear test sites in Nevada. Other studies have focused 
upon radiation exposure in Colorado and Utah. Those studies, 
which have been sponsored by the Department of Energy, the 
National Academy of Sciences, and state and local health 



93 



Dr. James B. Wyngaarden 
PaRo 2 



departments, have suggested a possible association between the 
test sites and the higher incidence of cancer. Accordingly, it 
would be appropriate for the NIH, as the foremost biomedical 
research center in the world, to address the question of whether 
a causal connection does or does not exist. And I would suggest 
that such an undertaking use as its first "models" for evaluation 
the TMI and Pilgrim I cases which I have described. 

You know of my continued confidence in the high quality 
work of NIH. I look forward to learning the results of your 
examination of this critical health issue. 




Edward M 
Chairman 






94 



DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service 

V National Institutes of Health 

I \ National Cancer Institute 

Ta Bethesda. Maryland 20892 

^ JIN < ^: -mi 



The Honorable Edward M. Kennedy 
Ufiited States Senate 
Wasfiington, D.C. ^OSin 

Dear Senator Kennedy: 

I am pleased to respond to your Ijtter of January 7, 1988 regarding potential 
health risks associated with low-level radiation. Specifically, you raised 
concerns about the health consequences of nuclear power plant accidents, adverse 
effects related to nuclear power plant operations, and cancer risks linked to 
radioactive fallout from nuclear weapons testing. 

The National Institutes of Health is actively involved in studying the adverse 
effects of ionizing radiation, and we concur with your view that the risks at 
low lavels need further clarification. We know, of course, that radiation can 
cause cancer, but the biological effects of quite low levels are a subject of 
current scientific conjecture. Recause new information relevant to the 
assessment of low-level risks will be available within the next one or two 
years, we do not believe public '^tscussions at this time would oe as fruitful as 
they might be in the future. Our reasoning is discussed below. 

The descriptive studies of leukemia clusters around the Pilgrim power plant in 
Massachusetts, and several plants in the United Kingdom, have led us to initiate 
a large-scale evaluation of cancer deaths occurring among persons living near 
the over 100 reactors operating in the ilnited States. We are correlating county 
mort»'ity data from the 1950s through early 1980s with reactor operations to 
determine whether the previous reports might be chance occurr-ences based on 
small numbers, or whether there might be valid reasons for concern. This 
evaluation should be completed within about one year. 

One of the major radioactive isotopes emitted during nuclear power plant 
operations, and from nuclear weapons testing, is iodine-131. For the past three 
years we have been collaborating with Swedish colleagues on a study of 40,000 
patients given low doses of iodine-131 for diagnostic reasons. This large study 
will be finished within one year and will prove invaluable in estimating the 
possible adverse effects from this environmental contaminant. We have also 
evaluated descriptive mortality data regarding possible cancer risks in the 
general population living downwind of the Nevada nuclear test site. While many 
reported associations are unsupported by these data, a small increase in 
leukemia in southwest Utah cannot be ruled out at this time. Our contract- 
supported study with the University of Utah should provide more definitive 
answers within the next year. Finally, staff members have conducted studies of 
the military personnel participating at nuclear weapons tests, and have 
confirmed that leukemia was increased above expectation, but apparently only for 
participants at one test series. No excess -mortal ity from other malignancies 
was found among participants at any test series. 



95 



Page 7. - The Honorable Edward M. Kennedy 

The most serious health impact of the Three 'lile Island (TMI) accident that can 
be identified with certainty is mental stress to those living near the plant, 
particularly pregnant women and families with teenagers and young children. 
Although increased risks of cancer, birth defects and genetic abnormalities are 
potential long-term consequences of low-level irradiation, few if any such 
effects are likely. The average dose of radiation to the 36,000 people living 
within a five-mile radius of the plant was only ?-R mrera, or approximately what 
might be received from natural background radiation within one or two weeks. 
There is no serious possibility that this dosage would result in any deleterious 
effects that could be detected epidemiologi cal ly. (In contrast, at Chernobyl in 
the USSR the average dose to the ?4,ono people living near the reactor was 
estimated as 44,000 rarem.'l The Pennsylvania Oepartment of Public Health, in 
consultation with the Centers for Oisease Control, however, is conducting 
periodic health and behavior surveys of the population living near TMI. 
Although psychological effects are temporary in most individuals, the ultimate 
impact of these effects remains to be fully assessed, as does the degree to 
which they may differ from those caused by other accidents or disasters. The 
mental stress following T'^I, of course, has been aggravated by the fear that a 
larger release of radiation might take place, with consequences that could be 
disastrous as now exemplified by the Chernobyl accident. While we are thankful 
that such an event has not occurred in the United States, we should profit from 
these experiences by taking steps to minimize the risks of such accidents in the 
future. 

Finally, within two years the National Academy of Sciences and the United 
Nations will complete their next reports on the biological effects of low-level 
radiation. We are also awaiting the publication of these scientific documents 
before embarking upon our next revision of the Radioepidemiological Tables 
mandated by Congress. 

It is important to stress that useful information about very small health 
effects, like those associated with very low levels of radiation, is extremely 
difficult and expensive to obtain. An indirect approach, such as studying 
populations with higher-level exposures and extrapolating the results to lower 
levels, tends to be far more productive. For example, studies of the workers at 
nuclear power plants would be particularly informative because the doses, though 
low, would be higher than to the general population, and cumulative doses could 
reach levels where radiation effects might be detectable, ^y law, radiation 
doses ^n recorded on individual workers, and we have contacted the Nuclear 
Regulatory Commission about the value of creating a registry of the almost 
100,000 workers they monitor each year in the United States. Your encouragement 
and support for the development of such a registry would be invaluable and 
greatly appreciated. 

In closing, I appreciate your continued support for our medical research 
program, and I will keep you informed on developments in the area of radiation 
studies as results from our investigations become available. 

Si ncerely , 



James (i. Wyngaarden, M.O. 
Director 



■ <»^* f < « «. 



96 

I think the National Institutes of Health probably has as good a 
capability and capacity to do that as any in the country. Hopefully, 
they will coordinate their work with the State officials and local 
officials as well. 

I would hope that they would be able to call on much of the ex- 
pertise that we have heard this evening and other expertise as well 
in their consideration. 

Let me ask, because we want to move on, Mr. Abbott, about one 
suggestion that has been made which is whether we ought to have, 
create independent of the NRC, an independent body to oversee the 
public health aspects of nuclear plant radiation releases. I don't 
know if you have any opinions about that. I don't know quite how 
we would set it up. 

Mr. Abbott. Well, Mr. Chairman, there is a definite perception 
of the public that the NRC is still promoting nuclear power, rather 
then being most concerned about the health and effect of nuclear 
power. 

I think part of what I was trying to express was that the percep- 
tion of the public was that really nothing was being done to protect 
it, and I don't think we have any comfort level that the NEC is 
doing it. Whether — I have pleadings to the State of Massachusetts 
to have another Federal agency which is to be kept totally inde- 
pendent of the promotion of nuclear power; then that might do the 
job. 

The Chairman. I noted your testimony, Mary Ott, with regards 
to the difficulties that you had in getting information, having to 
run through the Freedom of Information Act to get that, that is 
obviously enormously discouraging. I don't know whether you have 
any reaction to some independent health advisory group to monitor 
these types of activities. 

Of course, we would have to decide who appoints it; who it is ac- 
countable to, and whether we are just creating more bureaucracy, 
but maybe you can give some thought to it. We might try to circu- 
late some suggestions along those lines and try to get some of your 
reaction to them. 

And, Anne, I'm still troubled by your report in terms of how any 
evacuation plan is going to have to deal with some of those who 
have physical or mental limitations. You, as I understand, have 
made those representations to FEMA, have you? 

Ms. Waitkus-Arnold. FEMA, yes. 

The Chairman. And I understand that one of the major conclu- 
sions FEMA reached when they withdrew their approval was that 
the evacuation plan contained inadequate planning for the evacu- 
ation of the special needs population. 

Ms. Waitkus-Arnold. Right. 

The Chairman. And I think you should take some sense of satis- 
faction that someone at least listened to what, I think, is really one 
of the most provocative, unbelievable things that I've heard in pre- 
paring for the hearing. I must say I was absolutely dumbfounded. I 
should probably have known about it, but I think it must have 
stirred the heart and soul of any citizen to think that that's the 
way we're going to treat our fellow citizens, particularly those who 
are facing some physical challenge. 



97 

I want to thank all of you very much. You have been extremely 
helpful. I think the questions that you have raised have enormous 
potential impact for the people living in the area and throughout 
the state. We're very grateful to all of you for your hard work. It is 
quite clear from your testimony and from your fuller statements 
the amount of time and the expertise that you have put into this 
consideration, not only yourselves, but with your fellow citizens. It 
is really citizenship at its very best. 

I'm grateful to you, and I will take the liberty, when I talk to Dr. 
Wyngaarden, to mention each of you, and to send along your testi- 
monies, and, hopefully, NIH will have your input when they do 
their work. I want to thank all of you for your presentations. 
Thank you very much. 

[Applause.] 

The Chairman. Our next panel is comprised of some representa- 
tives and public officials who represent people who live in this 
area, and also the representative of one of our foremost public in- 
terest organizations. All of these witnesses have worked long and 
hard on Pilgrim I questions. I welcome them here this evening to 
share with the committee their judgments and concerns. 

First, we have Senator Bill Golden, who I'm sure is no stranger 
to any of you nor to me. Bill has been unrelenting in his attention 
to Pilgrim and I look forward to his testimony. 

We'll also hear from State Representative Larry Alexander, who 
has previously testified before Congress on Pilgrim. Peter Forman, 
State Representative from Plymouth, who led a state legislative 
committee effort on the subject of Pilgrim; David Malaguti, who is 
the chairman of the Plymouth Board of Selectmen, and who has 
devoted a lot of time on the issue; and Ms. Rachel Shimshak, from 
the Massachusetts Public Interest Research Group, an organization 
which over the last several years has issued three major reports 
dealing with the Pilgrim I plant. 

I welcome all of you here and look forward to your presentations. 
Why don't we go left to right. Three minutes each. 

STATEMENTS OF LAWRENCE ALEXANDER, STATE REPRESENTA- 
TIVE; PETER FORMAN, STATE REPRESENTATIVE; DAVID MALA- 
GUTI, CHAIRMAN OF THE PLYMOUTH BOARD OF SELECTMEN; 
AND RACHEL SHIMSHAK, MASSACHUSETTS PUBLIC INTEREST 
RESEARCH GROUP 

Mr. Alexander. Thank you, Senator. I also would like to thank 
you for this opportunity, and I have some additional materials 
which I would like to offer to your committee, as an appendix, 
along with copies of my testimony. 

As chairman — house chairman of the Massachusetts Legisla- 
ture's Joint Committee on Energy 

The Chairman. Wait a second. I forgot to swear you in. 

[Applause.] 

[Witnesses sworn.] 

Mr. Alexander. Well, if that's the case, let me change my 
speech. [Laughter.] 

Just kidding. 



98 

Senator, I testify today with great appreciation for your concern 
about this very important subject. I'm State Representative Larry 
Alexander. I'm house chairman of the Legislature's Joint Commit- 
tee on Energy, and I believe that there are two significant issues 
associated with nuclear power that warrant major Federal investi- 
gations immediately. 

First, Congress should order an in-depth, nationwide analysis of 
whether people suffer adverse health consequences as a result of 
living near nuclear powerplants. I was delighted to hear about your 
request to the National Institute of Health in that regard. 

Second, I believe that Congress should order an intense investiga- 
tion of the safety systems that operators of European nuclear reac- 
tors have added to their nuclear powerplants to determine whether 
operators of American nuclear powerplants should make similar 
modifications. 

Let me discuss each of these two issues in a little more detail. 
First of all, with respect to the health effects of living near nuclear 
reactors, there is an increasing body of scientific evidence that 
seems to suggest that routine and accidental releases of radiation 
from nuclear reactors may be causing increased leukemia, cancer, 
infant mortality, congenital defects and other adverse conse- 
quences. 

For that reason, I filed a bill to have Massachusetts set its own 
standards for radioactive emissions from nuclear powerplants, 
which it is allowed to do under federal law. I'm pleased to say the 
bill passed the House, but it has failed to pass the Senate yet, but I 
hope that ultimately, we'll be able to pass that law. 

The Massachusetts Department of Public Health has found sta- 
tistically significant increased incidences of leukemia in communi- 
ties near the Pilgrim reactor. There was a 59-percent increase in 
blood disorders, including leukemia, for Plymouth, Kingston, Dux- 
bury, Marshfleld, and Scituate for the years 1982 through 1984. In 
1985, there were three times as many cases of these blood disorders 
than would normally be expected for women in Plymouth — six 
cases instead of two — and the total increase for the five towns from 
1982 through 1985 was a statistically significant 43 percent. 

Dr. Sidney Cobb, whom you alluded to earlier, found that there 
seemed to be an increase in infant mortality and congenital defect 
rates that took place in coastal communities adjacent to or north of 
Plymouth soon after significant radioactive emissions were dis- 
charged from Pilgrim in the 1970's. 

There also seems to be some evidence of perhaps increased leuke- 
mia for people living downwind from Maine and Connecticut reac- 
tors. And there was a recent study in Lancet magazine suggesting 
a possible correlation between proximity to nuclear power plants 
and increased leukemia incidences in England. 

Therefore, I hope that Congress will do a major analysis of this 
issue on a nationwide basis to put this issue to rest one way or the 
other for citizens who live near those nuclear powerplants. 

Let me turn now briefly to the issue of nuclear reactor safety, 
particularly with reference to the General Electric Mark I reactor 
found at Pilgrim. I have serious doubts about the adequacy of the 
containment structure at Pilgrim. 



99 

Many European reactors have safety features that American re- 
actors don't have. Some, for instance, have a filtered vent to pre- 
vent overpressurization and a consequent breach of containment. 
The filters trap most of the radiation. 

My understanding is that Boston Edison does not plan to put any 
filters in the vents that it is going to put in at the Pilgrim plant. I 
find that strange. Even the owners of the Shoreham reactor in 
Long Island have announced their intention to install a filtered 
vent, and I fail to see why the Pilgrim owners do not plan to do so 
as well. 

Many European reactors also have an additional, independent 
decay heat removal system that serves as a type of backup cooling 
system in case of failure of the original residual heat or emergency 
core cooling system. Some of the European systems have done that, 
and yet Boston Edison has not seen fit to install this system here. 
If it's good enough for some of the European plants, I wonder why 
it is not good enough to have here. 

A federal investigation, preferably independent of the NRC, 
should be undertaken immediately of the filtered vent, the bun- 
kered RHR system, and other European safety systems to deter- 
mine whether they should be added to American nuclear power- 
plants. 

Congress should also consider requiring construction of a second 
steel-reinforced concrete containment structure and molten core 
barriers before General Electric Mark I-designed plants, such as 
Pilgrim, are allowed to continue to operate. Pilgrim should also not 
be allowed to restart unless the Governor reaches a threshold de- 
termination that an evacuation plan can adequately protect public 
health and safety, and local officials and the Governor have ap- 
proved such a plan. 

Let me add one final word with regard to Pilgrim. I am becoming 
more and more convinced that we may not need the power from 
Pilgrim. 

Boston Edison's own forecast of electric supply and demand 
shows that it probably won't need Pilgrim power from 1990 to the 
year 2000. With conservation and energy produced by small-power 
facilities, we may not need electricity from Pilgrim. 

So, therefore, all of us should ask ourselves why we should take a 
risk that we don't have to take. All of us should ask ourselves the 
ultiniate question, do we really need to take the risk of Pilgrim re- 
opening when we may not even need the power it might produce? 

[Applause.] 

Thank you very much. 

[The prepared statement of Mr. Alexander follows:] 



100 




LAWRENCE R. ALEXANDER 

REPRESENTATIVE 

exM ESSEX DISTRICT 

5-* LONGVIEW DRIVE 

MARBLEHEAO MA OI919 

TEL 631.7646 



ADM 



iiSTRATivE Assistant 
MELISSA eURKE 



HOUSE OF re:pre:sentatives 

STATE HOUSE. BOSTON 02133 



Charrman 
Commtllee on Energy 

ROOM 640 STATE HOUSE 
Teu 722-2090 

Research Director 
MICHAEL ERNST 



TESTIMONY OF STATE REPRESENTATIVE LAWRENCE R. ALEXANDER, 

HOUSE CHAIRMAN OF THE MASSACHUSETTS LEGISLATURE'S JOINT COMMITTEE ON ENERGY, 

BEFORE THE LABOR AND HUMAN RESOURCES COMMITTEE OF THE UNITED STATES SENATE 

JANUARY 7, 1988 



I would like to thank you, Mr. Chairman, and the members of this committee, 
for your deep concern over this issue and for holding this important hearing 
here in Massachusetts so that you can hear directly from the citizens who 
are most affected by the Pilgrim nuclear power plant. 

As House Chairman of the Joint Committee on Energy of the Massachusetts 
Legislature, I believe there are two significant issues associated with nuclear 
power that warrant major federal investigations immediately. 

First, Congress should order an in-depth nationwide analysis of whether 
people suffer adverse health consequences as a result of living near nuclear 
power plants. 

Second, Congress should order an intense investigation of the safety 
systems that operators of European nuclear reactors have added to their nuclear 
power plants, to determine whether operators of American nuclear power plants 
should make similar modifications. 

Let me discuss each of these matters in more detail. 

With respect to the health effects of living near nuclear reactors, there 
it an increasing body of scientific evidence that seems to suggest that routine 



101 



and accidental releases of radiacton from nuclear reactors may be causing 
increased leukemia, cancer, infant mortality, congenital defects and other 
adverse consequences. 

The Massachusetts Department of Public Health has found a statistically 
significant increased incidence of leukemias in communities near the Pilgrim 
reactor. There was a 59 percent increase in blood disorders including leukemias 
for Plymouth, Kingston, Duxbury, Marshfield and Scituate for the years 1982 
through 1984. In 1985, there were three times as many cases of these blood 
disorders than would normally be expected for women in Plymouth (6 cases instead 
of 2), and the total increase for the five towns from 1982 through 1985 was 
a statistically significant 43 percent. 

Dr. Sidney Cobb, the distinguished epidemiologist who originally identified 
this increase in leukemias, has also found that an increase in infant mortality 
and congenital defect rates took place in coastal communities adjacent to 

or north of Plymouth soon after significant radioactive emissions were discharged 

2 
from Pilgrim in the 1970's. Evidence also seems to suggest some increased 

3 
leukemias for people living downwind from Maine and Connecticut reactors. 

Dr. Bailus Walker, President of the American Public Health Association, and 

a former Massachusetts Commissioner of Public Health, has recommended a regional 

analysis of the health consequences of living near nuclear reactors. 

Dr. Jay Gould recently released a national study revealing higher infant 

4 
and fetal mortality rates in counties close to boiling water reactors. He 

believes that emissions from nuclear reactors are associated with nearly 9,000 

5 
excess deaths each year. 

The United States is not the only country in which studies show possible 

adverse health consequences for people living near nuclear power plants. 

A 1987 study in Lancet magazine suggests a significant correlation between 

proximity to nuclear power plants and increased leukemia incidence in England. 



102 



Other studies also suggest a need for further investigation. 

While it is very difficult to prove a definite causal link between the 
50 million curies of radioactive emissions released from American nuclear 
reactors and the specific adverse health effects that people have suffered, 
the growing body of epidemiological evidence suggesting the possibility of 
such a link makes it imperative that we explore this issue in more detail. 
The only way to do this thoroughly is for Congress to order a comprehensive 
nationwide epidemiological study of this matter immediately. 

Let me now turn to the issue of nuclear reactor safety, particularly 
with reference to the General Electric Mark I reactor found at Pilgrim. I 
have serious doubts about the adequacy of the containment structure at Pilgrim. 

Former NRC Commissioner James Asselstine has stated, "America can expect 
to see a core meltdown accident within the next 20 years, and it is possible 
that such an accident could result in off-site releases of radiation which 
are as large as, or larger than, the releases estimated to have occurred at 

o 

Chernobyl." American reactors, he notes, "were not designed to withstand 

9 
large-scale core meltdowns." 

Many European reactors, on the other hand, have safety features that 
American reactors do not have. Some, for instance, have a filtered vent to 
prevent overpressurization and a consequent breach of containment. Their 
filters trap most of the radiation. The owners of the Shoreham reactor in 
Long Island have announced their intention to install such a filtered vent. 
Pilgrim should not restart until and unless Pilgrim has such a filtered vent. 

Many European reactors have an additional, independent decay heat removal 
system that serves as a back-up cooling system in case of failure of the original 
residual heat removal (RHR) system and of the emergency core cooling system. 
This back-up system is also independently powered in case of station blackout 
and is "bunkered" underground to protect against earthquake damage and sabotage. 



103 



S«iss authorities have started retrofitting some Swiss reactors with this 
system, including an older boiling water reactor. 

The Pilgrim reactor was shut down in 1986 due to failures of the RHR 
system. It does not have a back-up, bunkered RHR system. If Europeans are 
installing additional cooling systems in their boiling water reactors, why 
shouldn't Boston Edison install the same system to provide more protection 
against meltdowns at the Pilgrim reactor? Boston Edison should install a 
bunkered RHR system at Pilgrim before restart. 

A federal investigat ion--preferably independent of the NRC--should be 
undertaken immediately of the filtered vent, the bunkered RHR system, and 
other European safety systems to determine whether they should be added to 
American nuclear power plants. Congress should also consider requiring construction 
of a second steel-reinforced concrete containment structure and molten core 
barriers before General Electric Mark I-designed plants such as Pilgrim are 
allowed to continue to operate. Pilgrim should also not be allowed to re-start 
unless the Governor reaches a threshold determination that an evacuation plan 
can adequately protect public health and safety, and local officials and the 
Governor have approved such a plan. 

Let me add one final word with regard to Pilgrim. I am becoming more 
and more convinced that we may not need the power from Pilgrim. Boston Edison's 

own forecast of electric supply and demand shows that it probably won't need 

12 
Pilgrim power from 1990 to 2000. With conservation and energy produced 

by small-power facilities, we may not need electricity from Pilgrim. 

All of us should ask ourselves why we should take a risk that we don't 
have to take. All of us should ask ourselves Che ultimate question--do we 
really need to take the risk of Pilgrim re-opening when we may not even need 
the power it might produce? 

Thank you very much. 



104 



FOOTNOTES 

1. "Health Surveillance of Che Plymouth Area," Mass. Department of Public 

Health, March 16, 1987. (Appendix A) 

2. "Testimony of Sidney Cobb, M.D.," presented to the Joint Committee on Energy, 

March 24, 1987. (Appendix B) 

3. Ibid. 

4. "Nuclear Emissions Take Their Toll;" Gould, J.M. et al; Council on Economic 

Priorities Publication N86-12; December, 1986, p. 7. (Appendix C) 

5. Ibid., p. 9. 

6. "Cancer Near Nuclear Installation," Beral, V., Lancet , March 7, 1987, p. 

556. (Appendix D) 

7. Bibliography of over 100 relevant research papers. (Appendix E) 

8 "Testimony of Commissioner James K. Asselstine, U.S. N.R.C., before the 

Subcommittee on Energy Conservation and Power of the Committee on Energy 
and Commerce," May 22, 1986, p. 3. (Appendix F) 

9. Ibid. 

10. "International Nuclear Reactor Hazard Study," Anderson, R. et al. Volume 

II, September, 1986; v, , .. 

"Europeans Head Toward Filtered Vented Containments after Chernobyl, 
Nucleonics Week , June 12, 1986. 

11 "Muehleberg Begins Backfit for Bunkered Emergency Cooling System," Nucleonics 

Week November 13, 1986. Telephone conversations between staff of Commissioner 
:KIi^lstine, November, 1986, and staff of Joint Committee on Energy. 

12 "Conservation and Load Management," Boston Edison, Exhibit V-1 ("Boston 

Edison's Long Range Resource Plan:" Between 1990-2000, Boston Edison 

will have more than 500 MW of capacity beyond its reserve capacity needs-Boston 

Edison receives less than 500 MW of capacity from Pilgrim), submitted 

to the Department of Public Utilities in November, 1987. (Appendix G) 



105 

The Chairman. Provocative. [Laughter.] 

Representative Forman. 

Mr. Forman. Thank you, Senator. My name is Peter Forman. 
I'm the State representative for Plymouth and Kingston; I'm a resi- 
dent of Plymouth. I recently served as house chairman of the legis- 
lature's Joint Special Committee to investigate the plant. 

I want to congratulate you for this hearing. While many state 
and local officials have been quite vocal and active trying to keep 
pressure on the NRC, it is obvious that there is little state or local 
jurisdiction over nuclear plants, and is almost exclusively under 
Federal control. As such, we are very pleased that you have taken 
this initiative. 

I understood from your staff that the focus of the hearing was 
not so much on Edison's performance, rather the performance of 
the federal agency, particularly the NRC, who regulates the utili- 
ties. So I would like to offer a few broad observations about the 
NRC's work. 

One of the most commonly heard criticisms is that the NRC is 
too much an advocate to nuclear power and not a watchdog. I 
would like to give you two examples of how I think some of the 
NRC's thinking is oriented to keeping the plants open. 

The first is the lack of decommissioning plans. In the many 
meetings held, we have come away with a sense that one reason 
NRC is reluctant to close any plant is because nobody seems to 
know what to do with the plant once it is closed. That sort of per- 
petuates an interest in making sure that they are open so those 
very tough questions don't have to be addressed immediately. 

I would urge, as a previous witness has, that Congress and the 
Administration not allow any delay in selecting a Federal disposal 
site because I think that's one of the reasons we don't want to ad- 
dress the issue of decommissioning. 

In the meantime, though, I think everyone would be well served 
with decommissioning plans for power plants, including Pilgrim, 
and I would like to urge the NRC and Boston Edison, along with 
any State, Federal, and local officials to begin planning for decom- 
missioning, so area residents and ratepayers and State officials will 
know what's in store for us when a plant is permanently closed. 

The second example of NRC gravitation toward keeping plants 
open is their grading system of plants' performance. We're all fa- 
miliar with the SALP reports and their three performance ratings. 
None of these rating categories include failures or fail rates. There 
are no objective criteria or performance ratings that would trigger 
a license revocation or a review of licensee performance. I think 
that the public and nuclear industry need to see clear standards as 
to exactly what constitutes a poorly run or a failing plant. 

The issues surrounding public health are, of course, paramount, 
but I get the sense that the NRC works in short-term, incident spe- 
cific reviews of whether or not a plant is responsible for any threat 
to public health. I would urge the Congress, or an agency other 
than the NRC, begin some sort of comprehensive, long-term studies 
to the public health impact, if any, around nuclear powerplants. 
These studies should include the exposure to health histories, as 
well as the cumulative exposure to the general public. 



106 

I would like to make another general observation about work 
place safety not related to radiation exposure. Not too long ago, 
Edison had a project to remove asbestos from the plant. One of the 
plant employees suggested to me that the work was poorly done 
and that there was unnecessary risks of asbestos exposure to the 
employees in the area. Questions were raised about as OSHA's abil- 
ity to supervise or investigate this problem. And I think some work 
needs to be done to insure that the NRC regulations and the indus- 
try standard to reduce radiation exposure, as well as NRC's almost 
exclusive jurisdiction over nuclear plants, does not reduce nonra- 
diation related workplace safety standards. 

On another matter, questions have been raised about the rela- 
tionship with contract workers in the plant; who do they answer to, 
what kind of quality control is achieved and how well do they work 
with other employees, and understand the NRC regulations. I 
would hope that the NRC will conduct some sort of fuller investiga- 
tion into those questions. 

As house chairman of the Joint Special Legislative Committee 
dealing with Pilgrim, there were two matters that we simply were 
not able to resolve. One was the issue of Mark I designs. Is there, 
in fact, an increase of containment failure in a Mark I design? Do 
these higher risks, if any, compensate for some other measures? 

The other is over charges of past releases. And Mr. Abbott, I 
think, has probably done the best job in documenting one such re- 
lease in 1982. 

Should the NRC refuse an adjudicatory hearing on Pilgrim's li- 
cense, then, at least I hope the NRC, or your committee, would 
have some sort of hearings on these two issues because these are of 
critical concern to the area residents, and we simply do not have 
the resource in our State legislature to begin sorting out the issues 
of past releases or the Mark I containment issue. 

Finally, I would like to very quickly touch on the issue of emer- 
gency preparedness. The NRC has created what, I think, is a real 
jurisdictional mess over the issue of emergency preparedness. By 
requiring local approval of plans, the NRC may or may not have 
given States the power to close plants. How far this power actually 
goes is unclear, but I think it is in everyone's interest that it needs 
to be clarified, clarified preferably by Congress, not the NRC. This 
should be done as soon as possible, so that state officials will have 
some sense as to how much power, if any, state and local officials 
have in closing a plant and preventing a plant like Pilgrim from 
coming back on line or preventing one from opening up through 
the use of the emergency preparedness plans. 

Again, Senator, let me congratulate you for focusing some con- 
gressional attention on this, and particularly on the NRC and its 
role as a federal regulator. 

[The prepared statement of Mr. Forman follows:] 



107 



TESTIMONY OFFERED BY 

STATE REPRESENTATIVE PETER FORMAN 

BEFORE THE SENATE COMMITTEE ON LABOR AND HUMAN RESOURCES 

JANUARY 6, 1988 




108 



Wi^t Cotranottfoeallif nf ,i3!lassacI{U2ctts 

^iouse of ^eptfsentniib^ 
,^tat£ ^mise, Boston 02133 



PETER FORMAN 

1ST PLYMOUTH DISTRICT 

1 MT PLEASANT ST 

PLYMOUTH MA 02360 

TEL. 746-0344 

ROOM 40, STATE HOUSE 
TEL. 722-2240 



Commiltees on 

Health Care 

Insurance 

Special Commilteei on 

Reapporiionmenl 

Pilgrim Nuclear Power Planr 

MARGARET GARDNER 
LEGISLATIVE ASSISTANT 



Senator Kennedy: 

My name is Peter Forman . I am the State Representative 
for Plymouth and Kingston and a resident of Plymouth. 
Recently, I served as House Chairman of the Legislature's 
Joint Special Committee to Investigate the Pilgrim Nuclear 
Power Plant. 

Let me congratulate you for this hearing. While state 
and local officials have been quite vocal and active in 
keeping pressure on Edison and the NRG, it is obvious that 
there is little state or local jurisdiction over nuclear 
plants. This is a matter of almost exclusive federal control 
and as such we are pleased to see Congressional attention 
being focused on this issue. 

I understand from your staff that the intent of this 
hearing is not so much to review Pilgrim's history or to 
investigate the work Pilgrim has been doing. Rather, it 
is to review the performance of the federal agencies, 
specifically the NRC , in regulating Pilgrim. 

One of the most commonly heard criticisms is that the 



r^ .. „.. . 1 , 



109 



enough of a watchdog. Let me give you two examples of how 
NRC thinking is oriented to keeping plants open. One is 
the lack of de-commissioning plans. 

From the many meetings held on Pilgrim, I have come 
away with a sense that one reason NRC is reluctant to close 
plants is because nobody seems to know what to do with a 
plant once it has been closed. Clearly, part of the problem 
is the lack of a permanent disposal or storage site for 
the high-level waste. This issue needs to be addressed 
and I hope that neither the Congress nor adminisitration 
will allow any further delays on selecting a federal site. 

In the meantime, though, everyone would be well served 
to have decommissioning plans for power plants. I would 
like to urge the NRC and Boston Edison, along with state 
and local officials, to begin planning for decommissioning. 
Area residents should know what will be done with a 
permanently closed site. Likewise, the state and utility 
ratepayers should know the expected cost of decommissioning. 

The second example is of NRC grading of plant 
performance. As we have seen in the SALP reports, there 
are three performance ratings. None of the three is a failing 
grade. There are no objective criteria on performance that 
would trigger a license revocation or hearing to review 
licensee performance. The public and nuclear industry need 
to see clearer standards as to what constitutes a poorly 
run or failing plant. 



no 



The issues surrounding public health are, of course, 

the greatest concern. However, the NRC seems to work in 

short-term, incident-specific reviews of whether or not 
a plant is responsible for a threat to public health. 

The Congress, through an agency other than NRC, should 
begin comprehensive, long-term studies of the public health 
impacts, if any, of nuclear power plants. These studies 
should include employee exposure and health histories, as 
well as cummulative exposure risks to the general public. 

As you know, there has been an above-average occurence 
of certain cancers in the South Shore area. The State 
Department of Public Health is conducting a long overdue 
study. 

Frankly, I doubt there will be any definite conclusion as 
to the possible causes of this slight elevation - if in 
fact there is a cause. However, it would have been useful 
to have had long-term studies around other plants to see 
if there were common events, or what the history has been 
around other plants. 

Let me make another observation about general workplace 
safety. Not too long ago, Edison had a project to remove 
asbestos from the plant. An employee has suggested to me 
that the work was poorly done and there were unnecessary 



Ill 



risks of asbestos exposure. Quescions were raised about 
OSHA's ability to supervise and investigate this work. I 
think some work needs to be done to ensure that NCR 
regulations, the strict standards to reduce radiation 
exposure, and NRC ' s almost exclusive jurisdiction over nuclear 
plants does not reduce non-radiation work place safety 
standards . 

On another matter, questions have been raised about 
the relationship of contract workers in a plant. Who do 
they answer to? What kind of quality control is achieved? 
How well do contract workers work with regular employees? 
How well do contract workers understand and follow NRC 
regualtions? These are matters which I have not seen fully 
studied . 

There were two important matters in the Special 
Committee's work which we simply were unable to resolve. 
One was the issue of Mark I designs. Are there serious 
flaws? Can they be compensated by other measures? Is there 
an increased risk of containment failure in a Mark I? 

The second was an overcharge about part releases. The 
best documented charge is over the 1982 release already 
discussed by Mr. Abbott. We did not have the expertise 
or resources to determine what was released and over how 
large an area. 



112 



Should the NRC refuse an ad judicutory hearing on Pilgrim 
license then there should at least be NRC or Congressional 
hearings on these two issues. 

Finally, I would like to touch on the issue of Emergency 
Prepardness. The NRC has created a real jurisdictional 
mess over this issue. By requiring local approval of plans 
the NRC may or may not have given states the power to close 
plants. How far this power actually goes is unclear but 
it should be clarified preferably by Congress and as soon 
as possible. 

Senator, again let me congratulate you for focusing 
some Congressional attention on the role of the NCR and 
their performance. 



113 

The Chairman. Thank you very much. Senator Golden. 

Mr. Golden. Mr. Chairman, I want to thank you first for your 
continuing and long standing interest in this issue, and particular- 
ly for responding to the request of local officials to bring this hear- 
ing to us this evening. I particularly thank you for the opportunity 
to testify before you this evening. 

I believe that the Pilgrim nuclear power station should be closed 
for reasons of safety, reliability and economics. There is over- 
whelming evidence that you will hear tonight that it is one of the 
worse managed nuclear powerplants in the country. Its contain- 
ment vessel has been proven to be defective, no emergency plans 
exist to adequately protect the public in the event of a serious acci- 
dent at the plant. Evidence has also been mounting of serious secu- 
rity and radiological control problems at the plant, and a recent 
study has demonstrated that it would be less expensive to shut Pil- 
grim down than it would be to allow it to start up again; yet no 
level of government has acted decisively to shut this plant down. 

Under the Atomic Energy Act, States have almost no power re- 
garding the safety of nuclear powerplants. Federal authority, 
which is embodied in the Nuclear Regulatory Commission, has a 
virtual monopoly regarding the operation of nuclear plants. Unfor- 
tunately, the Nuclear Regulatory Commission has failed to distin- 
guish between plants that are safe and those that are not. 

Rather than providing a fair and open forum for resolution of 
nuclear safety concerns, as well as a mechanism for closing unsafe 
plants, the NRC has chosen instead to be an advocate of the nucle- 
ar industry. Despite all the well documented problems at Pilgrim, 
the NRC has chosen to keep the plant licensed. 

In July of 196— in 1986, I filed on behalf of myself and 49 other 
State legislators and Massachusetts, Public Interest Research 
Group and other players, a petition with the NRC requesting a 
formal hearing on suspension or revocation of Pilgrim's license to 
operate. Both the Government and the Attorney General has since 
filed similar show cause petitions with the NRC requesting hear- 
ings on the Pilgrim's license. 

The NRC's failure to consider fully and fairly and in a timely 
manner these petitions has convinced us that we cannot rely on 
the NRC to protect the public from the dangers presented by the 
Pilgrim nuclear power plant. We urge and respectfully request that 
you join our efforts by using the power of this committee to 
demand that the NRC hold formal hearings, so that Boston Edison 
may demonstrate why it should be allowed to operate a plant that 
is unsafe, unreliable and uneconomical. 

A year and a half ago, I testified at length before the Congres- 
sional Subcommittee on Energy Conservation and Power in Wash- 
ington, DC, on the problems at Pilgrim. Unfortunately very little 
has changed since that hearing, and the problems what I discussed 
in that testimony have not been resolved. Accordingly, I would like 
to submit that testimony again to your committee, and a copy of it 
has been submitted. ^ 



' The testimony referred to appears with the written statement. 



114 

The fact of the matter is, Senator, that we need your help. We 
are in a situation where we have a utility that plans to file for re- 
start of this plan even though they don't have the approved man- 
agement performance, even though there is no emergency plan to 
adequately protect the public, even though the containment vessel 
is flawed and we have a 90 percent rate of failure in the event of a 
serious accident of the plant, and even though radiological control 
problems seem to threaten the health of workers and the general 
public. The NRC has determinedly been an advocate for the indus- 
try. It has sought to shut out public participation. 

You have opened the door tonight to that public participation to 
state and local officials and the general public. We deeply appreci- 
ate it. We would ask that you continue that effort by using the 
power of this committee to request the NRC, in fact, hold an evi- 
dentiary hearing on why the license of the Boston Edison Co. 
should not be suspended or revoked. 

[Applause.] 

The Chairman. Excellent testimony. 

[Booing.] 

The Chairman. Voices of Boston Edison. Let me say we tried to 
get the NRC to have such a hearing with regard to Seabrook. We 
were unable to do so. We were joined by just about the whole con- 
gressional delegation — and also Senators from New York that — we 
work together, the Senators from New York [laughter] and we'll 
continue to try and do so. 

I really am troubled by the fact that we can't get such an open 
hearing. We are going to insist on it, as we did on Seabrook. I men- 
tioned earlier what I would do, if we're unable to get the NRC to 
open — I would certainly hope that they will. I will take every 
action I possibly can to see that they do. I know — I'm sure I speak 
for my colleagues. Senator Kerry and Congressman Studds. But if 
we're unable to do so, we certainly can testify. I give you my assur- 
ance I certainly will, and I'll bring all the testimony that we heard 
today and try to present it in as effective way as I possibly can. 
David Malaguti. Is that how it's pronounced? Did I say it right? 

Mr. Malaguti. 

Mr. Malaguti. Yes, Senator. As a matter of fact, you're just fine. 

Senator, I'm the chairman of the local Board of Selectmen, and 
on behalf of my board, I would welcome you to Plymouth. It is a 
pleasure and an honor to have you here. We would like to see you 
more often, perhaps, but it is indeed a pleasure. I'm afraid that at 
this point my testimony, some of it, might be old hat, but I think it 
is important enough to state again. 

The Plymouth Board of Selectmen has discussed at regularly 
scheduled and posted meetings and has taken the following posi- 
tion. The Pilgrim power station should not be permitted to restart 
until an effective radiological emergency response plan approved 
by the town of Plymouth is in place. I quote from the Board's letter 
to the NRC, dated September 2, 1987. 

The Plymouth Board of Selectmen recommends that the Pilgrim Nuclear Power 
Station located in our community not be allowed to restart until the radiological 
emergency response plan of this town is in an effective form. 



115 

That position statement was taken after receiving a first report 
of the town's Committee on Nuclear Matters dated March 1987, 
and on the advice of the civil defense director. Our position was re- 
iterated in a second letter to the NRC, dated November 16, 1987. 

Our present radiological emergency response plan dated May 1985, is inadequate, 
outdated and has serious deficiencies. While we are working hard to bring into 
being a new plant that would permit us to provide for the health and safety of our 
citizens during a radiological emergency, an approved plan does not exist at this 
time. It will take several more months of work before such a plan can be presented 
for the action of the Board of Selectmen. 

Senator, the magnitude of this problem can be glimpsed if you 
will just bear in mind two population figures. When Pilgrim station 
opened in 1972, the population of Plymouth was 19,000. Today it is 
in excess of 44,000. Our town is 17 miles in length. Stretching along 
the ocean, we have three major escape routes: Route 3A, Route 44 
and the Route 3 Expressway. All routes suffer from traffic grid- 
locks periodically, especially during the tourist season when people 
flock throughout our historic town. Winter storms, fall hurricanes, 
and other adverse weather conditions only exacerbate the problem. 

The town of Plymouth is in the best position to assess the pub- 
lic's safety. We are the population most at risk, and we have the 
experience of the years in dealing with disaster. No public utility 
must be permitted by the Nuclear Regulatory Agency to dictate a 
evacuation plan, thereby usurping the traditional powers and au- 
thority of the local elected officials. We are not about to surrender 
our rights to govern ourselves. We are united with our Massachu- 
setts civil defense director, our State public safety director and 
with our governor. We maintain, as did Governor Dukakis in his 
letter of December 17, 1987, that the Pilgrim nuclear power station 
should not be permitted to restart the reactor until all safety issues 
are resolved, and until adequate approved emergency response 
plans have been developed by this town and state. 

We recommend that your committee exert congressional pres- 
sure on the NRC to keep the Pilgrim nuclear power station closed 
until an effective town-approved emergency plan has been devel- 
oped for the safety of our citizens and for the protection of their 
property in this state. 

I thank you Senator for the opportunity to testify. 

[Additional material supplied follows:] 



116 



K ••.'. \ ,1 M. 1' ! !' 



\^./ iHK shL ;'rMi:N 



\\l' I 1\'.1 , c l.:i . 1 . .: .'. .11 . MM 

^.M-l 1 ir. I ■-; . I.I \i. i.: : i . , 'i i 



September 2, 1987 



Honorable Lando Zech 

Chairman 

Nuclear Regulatory Conmiission 

Washington, D.C. 20555 

Dear Chairman Zech: 

Please convey to the Nuclear Regulatory Commission the 
consensus of the Plymouth Boar^ of Selectmen which, simply 
stated, recommends that the pilgrim Nuclear Power Station 
located in our community not be allowed to restart until the 
Radiological Emergency Response Plan of this town is in an 
effective form. Our present RERP is dated May 1985 and is 
under intense revision. It is Inadequate as to response 
time, evacuation procedures, and reception centers. 

The recent FEMA report to the Nll^C documents the 
inadequacies of the Commonweal t'-> of Massachusetts' RERP. The 
Board of Selectmen recognizes ^he same flaws in the operative 
plans of this community. 

The public safety would be at risk if the Pilgrim Nuclear 
Power Station is permitted to open without a valid 
radiological emergency plan in place. 

We remind the NRC that this community of over 40,000 
citizens is entirely within the ten mile emergency planning 
zone and that our geographic location and our few and over- 
burdened evacuation routes pose serious problems in any 
emergency plan, whether for natural or radiological disaster. 

The issue has been well studied and documented by the Nuclear 
Matter Advisory Committee of this town as well as by our 
Civil Defense Director. 



117 



Ilonoi Jblo Latuio "f~:)<, Cli.:irmn:i 
NucJeor Rcqulatory CotnnisEiun 
3eptenibir 2, 1"87 
Page 2 



The Plymouth Board of Selectmen i ecommends that the Pilgrim 
Nuclear Power Station not be permitted to restart until an 
effective, tested Radiological Emergency Response Plan is in 
place. 

i 

The'public safety ought not to be placed at risk. 
Very truly yours, 

David F« Nalagutl, Chairman 

Board of Selectmen 

CO Secretary of Public Safety, HA 

Boston Edison, President <€weenev 



118 



■- 1 

• J' i 



M o \- • 



Tho.MaL- S. I'uriey. Di:.-eccor 

Office of iJuclcar Reactor Regulation 

Washington, D.C. 2C555 

Dear Di;. Murlcy: 

Thank y:>u for ■■our Novercber 2, 1987, letter As you noted in 
our letter of September 2, 1987, the Plymouth Board of 
Selectmen had arrived, at^. a ponsensus that the Pilgrim Nuclear 
Power Station ought not be granted permission to re-start 
until an effective Radiological Emergency Response Plan 
(RERP) was in place. An "effective plan" would be one 
acceptable to FEMA and bearingf*its approval. 

The Board reiterates this position and, in viev; of the August 
1987 report of the Federal Emergency Management Agency which 
withdrew interim approval of the existing RERP, the Board 
feels that the Town of Plymouth's RERP of May 1985 is not 
only seriously out-dated, but cannot be considered an 
adequate protection of the public safety during a time of 
potential radiological danger to our citizens. 

Wo, who are sworn to uphold the public safety, are in the 
best position to know the present status of planning and 
readiness in our community, and we ask you to consider our 
views above all others. It is our town, completely within 
the Emergency Planning Zone (EPZ) , and our citizens, who are 
most at r isk . 

To restate our position: The RERP for Plymouth is under 
intense revision and updating by our Civil Defense 
organization and our advisory committeec. Our present plan , 
dated May 1985 has serious deficiencies and it will take 
several nonths before a final draft can be brought to this 
Board for its consideration. 

The restart of the Pilgrim Nuclear Power Station under the 
foregoing conditions would be dangerous and not in the public 
vjelf are . 



119 



piGvicu.-..- :.;'.:cn p.o;-i:c;.d by trio c: oir.Tnu r. i t y ir cor.iijrictio;. 
witn t'.\c ri\il D^-'Lcr.de orgar i::ations cf the Ccni~.cnwealt:i o: 
Kassac'.v.:- :tcs , ui.c- ?ilcjii-i Kuclcai PowfJi' Station, v,-ith icE 
pact t: -.:.-. •lee", bisiccry, ought not be ferT.ittec^ to restart. 

Very t v ;. _" y y o i; r s , 

BOARD Cy SBLiCCTMEN 

David F. !:alGguti 
Chairman 



cc Peter 'vl . Agnes,- Jr., Assistant Secretary of Public Safety 
Robert J. Boulay, Directors' Mass . Civil Defense 
Peter Forraan, Representative 
Edward P.Kirby, Senator 

Stephen J. Sweeney, President; Boston Edison 
Dr. Grace Healy, Chairman; Nuclear Matters Committee 



120 

The Chairman. Ms. Shimshak. 

Ms. Shimshak. Thank you, Senator. It's an honor to testify 
before you tonight, and also to sit with so many distinguished legis- 
lative representatives, of which I'm not one. 

My name is Rachel Shimshak. I'm an advocate for Massachusetts 
Public Interest Research Group. MASSPIRG is a statewide organi- 
zation, working on consumer and environmental protection and 
energy issues. We have about 150,000 members across the State. I 
appreciate the opportunity to testify tonight about the historically 
troubled Pilgrim reactor. 

MASSPIRG has followed the problems of Pilgrim over the past 
decade and has conducted several studies on emergency planning 
issues and the economic benefits of closing the reactor and invest- 
ing in alternatives. I've brought with me copies of those reports 
and I would like to submit them for the record, if I could. 

In July of 1986, as Senator Golden mentioned, MASSPIRG, along 
with many state legislators, elected officials and dozens of citizen 
groups represented here tonight, submitted a show cause petition 
to the Nuclear Regulator Commission which detailed management, 
structural, emergency planning and radiological exposure problems 
at the reactor. MASSPIRG is certainly not alone in its criticism of 
the plan. Reports from the NRC, the Department of Public utilities, 
the Federal Emergency Management Agency, the State Depart- 
ment of Public Safety, and even Boston Edison's own review panel, 
the Hogan Commission, have detailed their criticism of Boston 
Edison's management and of Pilgrim's plant. If a horse had as 
many problems as the Pilgrim plant has, it would have been shot. 
[Laughter, applause.] 

It would be wise to acknowledge Edison's inability to correct 
these problems and to put the plant out of its misery by closing it 
permanently. 

Today I would like to focus my comments on the conclusions of 
an emergency planning survey released this fall entitled "No 
Exit". MASSPIRG's earlier reports generally looked at the adequa- 
cy of the emergency plans themselves. This report approached the 
emergency plans from a different angle. It looked not at the plans 
themselves, but at the people who would be asked to follow them. 
Such information is crucial to assessing the feasibility of the plan, 
particularly in light of the General Accounting Office's finding 
that, quote, "No Federal agency assesses public knowledge of radio- 
logical emergency procedures." 

In the summer of 1987, MASSPIRG surveyed 363 residents of the 
Pilgrim emergency planning zone to determine what people knew 
about the official emergency plan, and whether they would follow 
those plans in case of an accident at the plant. 

The key findings of this survey show that residents are even less 
informed about Pilgrim emergency plans then they were at the 
time of MASSPIRG's last survey conducted in 1983. Moreover, they 
said they would refuse to follow official instructions in the event of 
an emergency. Let me just review a few of the findings of the 
report. 

First, residents have only a limited knowledge of emergency 
plans for their communities. Only 56 percent of those surveyed said 
that they had received the emergency public information booklet 



121 

from Boston Edison, the operators of the plant, compared with 67 
percent who remembered receiving the booklet in 1983. Moreover, 
only 23 percent of those surveyed said they had actually read the 
booklet, compared to 38 percent in 1983. 

Second, many residents would not follow the emergency plan in 
case of a serious problem at Pilgrim. For instance, the most 
common response to an accident at Pilgrim, about 27 percent of the 
people polled, would immediately evacuate; a direct contradiction 
of the instructions contained in the emergency information booklet. 
In nice big letters in the booklet, incidently. 

Second, only 19 percent of those questioned said that they would 
go to one of the designated reception centers in case of an evacu- 
ation, and two thirds of those few who would follow the emergency 
plan, would go to the Hanover Mall, which is no longer an official 
reception center. 

Perhaps the most stunning thing that we found concerned school 
age children. Of the 37 percent surveyed who had school age chil- 
dren, nearly half said that they would try to pick up their school 
age children from school in the event of an emergency. Again, pre- 
cisely what the emergency booklet instructed them not to do. Just 
9 percent of parents said that they would follow the instructions to 
meet their children outside the danger zone. And then, just for 
good measure, 79 percent of the respondents felt that Pilgrim 
should remain shut down if management and safety problems per- 
sist. 

Allowing the Pilgrim plant to reopen in light of these results and 
the serious management and safety problems that persist at the 
plant, would be like giving a drunk the keys to drive home. MAS- 
SPIRG recommends that the Pilgrim plant not be 

The Chairman. Did they indicate who those 9 percent parents 
were that were going to leave their children? [Laughter.] 

Ms. Shimshak. Nine percent said that they would actually 
follow, I 

The Chairman. I guess that doesn't say they would actually 
leave them. 

Ms. Shimshak. Right. 

The Chairman. It doesn't include, as I understand it, the chil- 
dren going to private schools; is that correct? 

Ms. Shimshak. There are currently no plans for those people. 

The Chairman. What do they do? Do they stay behind and take 
that wonderful tablet? 

Ms. Shimshak. Perhaps they could wait for the buses, for the 
buses to arrive from Boston to pick them up. 

The Chairman. A serious question. Do you know the number of 
children that would be in the private and parochial schools; are 
there many? 

Ms. Shimshak. I'm sure that there are, but perhaps you can. 

Mr. Malaguti. I don't have the numbers. 

The Chairman. OK, please continue. 

Ms. Shimshak. MASSPIRG recommends that the Pilgrim plant 
not be opened unless it is determined that, one: a workable plan 
can be developed; two: such plans have been effectively disseminat- 
ed and implemented, and three: that outstanding management, 
safety and economic questions have been resolved. 



122 

We also recommended that Boston Edison use this unique oppor- 
tunity to implement the conservation and load management recom- 
mendations of the Hogan report, rather than spend more money on 
this plant. Thank you. 

[The prepared statement of Ms. Shimshak follows:] 



123 



A4ifS5PIRG 

MASSACHUSETTS PUBUC INTEREST RESEARCH GROUP 

Testimony of 

Rachel Shlmshak 
Advocate, Massachusetts Public Interest Research Q*oup 

Before the 
Labor and Human Resources Committee of the United States Senate 



Concerning public health impacts associated with proposed restart of 
Pilgrim I nuclear power plant 



January 7, 1988 



29 Temple Place, Boston, MA 02111 (617) 292-4800 



124 



Good ev«nin(j, Mr. Cnairnan and members of the Committee. My naae is 
Rachel Shimahak and I an an advocate for the Massachusetts Public Interest 
Research O-oup (MASSPIRC). MASSPIRG is a statewide organization worlclng on 
consuoar and environioental protection and energy Issues. We have over 170,000 
citizen oembers across the state of Massachusetts. 

I appreciate the opportunity to appear before you today to discuss the 
historically troubled Pilgrim reactor. MASSPIRG has followed the problems at 
Pilgrim over the past decade and has conducted several studies on emergency 
planning issues and the economic benefits of closing the reactor and 
investing in alternatives. In July of 1986, MASSPIRG, along with 50 state 
legislators and over a dozen citizen groups, submitted a "Show Cause" petition 
to the Nuclear Regulatory Commission (NRC) which detailed management, 
structural, emergency planning and radiological exposure problems at the 
reactor . 

MASSPIRG is certainly not alone in its criticism of the plant. Reports 
from the NRC, the Department of Public Utilities, the Federal Emergency 
Management Agency, the state's Department of Public Safety, and even Boston 
Edison's own review panel (the Hogan Commission) have detailed their criticism 
of Boston Edison and the Pilgrim plant. If a horse had as many problems as 
the Pilgrim plant has, it would have been shot. In our Judgment, it would be 
wise to acloiowledge Edison's inability to correct these problems and put the 
plant out of its misery by closing it permanently. 

Today I would like to focus my comments on the conclusions of an 
emergency planning survey we released this fall entitled, "No Exit." 
MASSPIRG' 3 earlier reports generally looked at the adequacy of the emergency 
plans themselves. This report approached the emergency plans from a different 
angle — it looked not at the plans themselves but at the people who will be 
asked to follow them. Such information is crucial to assessing the 



125 



feasibility of the plana, particularly in light of the General Accounting 
Office's finding that "no federal agency assesses public knowledge of 
radiological emergency procedures." ( GAO Report to Hon. Edward J. Markey, 
House of Representatives, "Nuclear Regulation: Public Knowledge of 
Radiological Emergency Procedures," June 1987, p. 1) 

In the summer of 1987, MASSPIRG surveyed 363 residents of the Pilgrim 
emergency planning zone (EPZ) to determine what people knew about the 
official emergency plans and whether they would follow those plans in case of 
an accident at the plant. 

The key findings of this survey show that residents are even less 
informed about Pilgrim emergency plans than they were at the time of 
MASSPIRG's last such survey, conducted in 1983- Moreover, they refused to 
follow official instructions in the event of an emergency. 

Let me review a few of the findings in the report: 

1 ) Residents have only a limited knowledge of emergency plans for 
their communities. Only 55} of those surveyed said they had 

received the Emergency Public Information booklet from Boston Edison, the 
operator of the plant, compared with 57» who remembered receiving the booklet 
in 1983. Moreover, only 235 of those surveyed said they had actually read the 
booklet completely, compared to 38' in 1983. 

2) Many residents would not follow the emergency plans in case 
of a serious problem at Pilgim: 

• the most common response to an accident at Pilgrim (27? 

of those polled) would be immediate evacuation--a direct contradiction of 
instructions contained in the emergency information booklet; 

• only 19' of those questioned said they would go to one 

of the designated reception centers in case of an evacuation, and two-thirds 



126 



of these few who would follow the emergency plans would go to the Hanover 
Mall, which is no longer an official reception center; 

• of the 37S surveyed who have school-age children, 

nearly half iUSi) said that they would try to pick up their children from 
school in the event of an emergency — precisely what the emergency booklet 
instructs them not to do; just 95 of parents said they would follow the 
Instructions to meet their children outside the danger zone. 

* Seventy-nine percent of the respondents felt that Pilgrim should 
remain shut down if management and safety problems persist. 

Allowing the Pilgrim plant to reopen in light of these results and the 
serious management and safety problems that persist at the plant would be like 
giving a drunk the keys to drive home. MASSPIRG recommends that the Pilgrim 
plant not reopen unless it is determined that: 

1) workable plans can be developed; 

2) such plans have been effectively disseminated and implemented; and 

3) outstanding managment, safety, and economic questions have been 
resolved . 

We also recommend that Boston Ediston use this unique opportunity to 
implement the conservation and load managment recommendations of the Hogan 
report rather than spend more money on this plant. 

Thank you very much. 



127 

The Chairman. I want to move along, but I have some questions. 
First of the legislators. First of all, I congratulate you on the report 
that was made for the Joint Special Committee, and I'm going to 
make the recommendation contained in the report a part of the 
hearing record as well. 

Representative Forman spoke about the adequacy of the ability 
of local and State governments to deal with some of the NRC rul- 
ings. 

Do you have suggestions of ways in which the NRC should 
expand the role of the State and local communities? Or if you want 
to think about it, you can later make it a part of the record. 

[Excerpts from the report referred to above follows:] 



128 ' 



SENATE No. 2023 



Z'ht CommontDtaltt of 0iaMat!bnietti 



REPORT 

of the 

JOINT SPECIAL COMMITTEE 

ESTABLISHED FOR THE PURPOSE 

OF MAKING AN INVESTIGATION AND STUDY 

Relative to 

THE PILGRIM NUCLEAR GENERATING 
FACILITY AT PLYMOUTH 



(under the provisions 
of Senate Order No. 2044 
adopted in the year 1986). 



July, 1987 



129 
SENATE - No. 2023 

Z>f)t CommontDealtt ot 0iasiiad)ufitttii 



FOREWORD 



The Pilgrim Nuclear Generating Station has been shut down since 
April 1986. The Nuclear Regulatory Commission has been sharply 
critical of the Boston Edison Company's management of the plant. 

The Massachusetts Legislature responded with the establishment 
of a special joint committee to investigate and study the problems at 
the facility. This report is the culmination of the committee's work. 

We recognize that this is not the final work on Pilgrim. Debate over 
Boston Edison's improvements, possible re-start, and how fully our 
recommendations are followed will continue. We also recognize that 
state authority over nuclear power is limited. Thus our recommen- 
dations should be seen in that light. 

We do hope, however, that the report will serve as a major reference 
point as public debate continues and decisions are made. As Chairmen 
of the committee, our aim was to provide an open forum where all 
the issues could be reviewed objectively. 

We have succeeded in our efforts if the report contributes to the 
enhancement of public safety and public health in the 
Commonwealth. 

Finally, we wish to thank the committee members for their hard 
work and patience, as well as the individuals and agencies identified 
herein that contributed greatly to this report. 



SENATOR THOMAS C. NORTON, 
Senate Chairman. 



REPRESENTATIVE PETER FORMAN, 
House Chairman. 



130 
SENATE - No. 2023 [August 



This report has been prepared by Brian J. Prenda, 
M.P.A., Lisa Kaminski, Kevin Considine, Linda Marley 
and Liicy DeLaney for the Special Committee to 
investigate and study the Pilgrim Station Nuclear facility 
at Plymouth. 

The staff of the Special Committee extends its sincere thanks to 
those who so generously contributed their time and expertise to the 
preparation of this report. 



131 

1987] SENATE - No. 2023 97 

RECOMMENDATIONS 

I) Creation of the Division of Nuclear Facilities Safety. 

II) Endorsement of Comprehensive Load Management and 
Conservation Programs. 

Ill) Prioritize Massachusetts Based Electrical Generating 
Facilities. 

IV) Department of Public Utilities to Establish a Five-year 
Supply Plan without reliance on the Pilgrim Plant. 

V) Committee Review of the Nuclear Regulatory Commission 
(NRC) Systematic Assessment of Licensee Performance 
Report (SALP) and Recommended Measures to Correct 
Serious Functional Deficiencies at the Pilgrim 
Nuclear Generating Facility at Plymouth. 

VI) Improved Emergency Preparedness Plan. 



132 

98 SENATE — No. 2023 [August 

RECOMMENDATION I 

CREATION OF A DIVISION OF 
NUCLEAR FACILITY SAFETY 

After many hours of deliberation over topics such as emergency 
preparedness and planning, monitoring of radiation and other aspects 
of nuclear safety, the committee has concluded that many areas 
regarding public safety need immediate attention and improvement. 
After reviewing and hearing the testimony of the Department of 
Public Health (DPH) and the Department of Public Safety, the 
committee concluded that lack of funding, along with shortfalls in 
strict compliance with many sections of Chapter 796 of the acts of 
1979, have led to a less than appropriate handling of radiation 
monitoring and emergency preparedness. The committee, therefore, 
recommends that the Commonwealth adopt and implement the 
formation of a Division of Nuclear Facility Safety to oversee nuclear 
generated power production in the Commonwealth. 

The Division of Nuclear Facility Safety shall provide the following 
provisions and services: 

The Division of Nuclear Facility Safety shall be a division of the 
Department of Public Safety and shall be responsible for monitoring 
the operation and modification of the two nuclear power plants within 
the Commonwealth. In addition, it shall be responsible for developing 
emergency response plans in conjunction with Massachusetts Civil 
Defense for responding to accidents involving nuclear power plant 
facilities. Major activities shall include: installation, operation and 
maintenance of a system for remote monitoring of radioactive 
discharges from the nuclear power plants, in conjunction and under 
the supervision of the Department of Public Health; development and 
review of the Massachusetts Radiological Accident Emergency 
Preparedness Plan (MRAEPP); oversight of training of state and 
local civil defense personnel responsible for implementation of the 
MRAEPP. Enforcement of rules and regulations prescribing 
standards for in service testing of pressurized systems at nuclear power 
plants which the Department of Public Safety oversees. 

1) The Massachusetts Radiological Accident Emergency Prepared- 
ness Plan. 

The Massachusetts Radiological Accident Emergency Prepared- 



133 



1987] SENATE - No. 2023 99 

ness Plan shall establish a program for statewide, integral 
management procedures in the event of an accident which may occur 
at a nuclear power reactor site. The primary purpose of the plan is 
to provide a coordinated response by state and local governmental 
officials for the protection of the citizens of the Commonwealth. The 
plan shall include site specific planning to cover the urgency of 
protecting citizens living near nuclear plants; a concept of operations 
so that the plan can be effectively carried out; and an effective 
allocation of resources and personnel. The plan shall pre-assign the 
duties and responsibilities that would be taken by all the respondents 
to a nuclear accident thus enabling actions to be made quickly and 
efficiently. 

The Massachusetts Division of Nuclear Facility Safety and the 
Massachusetts Civil Defense Agency shall share the primary 
responsibility for developing the plan with integral component 
agencies such as the state police and the Emergency Planning Zone 
(EPZ) communities' local officials. The utilities' security and safety 
personnel must also play a major role in planning. Specifically, the 
Division of Nuclear Facility Safety shall be responsible for the 
technical functions of this effort, and the Civil Defense Agency shall 
be responsible for the operational aspects. The plan shall be reviewed 
every year for accuracy and proper appropriation to assure a fully 
functional quality plan. The appropriate components shall be 
distributed to the proper state, county and municipal agencies and 
organizations in the Commonwealth for implementation. 

The Division of Nuclear Facility Safety shall plan to expand the 
EPZ to 50 miles from each reactor with the understanding that greater 
planning and preparedness efforts are necessary closer to the reactor 
and that evacuation will not likely be recommended for all areas 
within a 50-mile radius. These plans should be tailored to meet each 
community's specific needs. 

The Division of Nuclear Facility Safety shall clarify evacuation 
plans for regional schools which have students from at least one, but 
not all, towns in the school system which are part of an EPZ. Division 
and Civil Defense officials working with school administrators and 
parents' groups must develop workable student and teacher 
evacuation plans and establish criteria for determining when, if ever, 
it would be appropriate to send children home first to evacuate with 
their families. 

The Division of Nuclear Facility Safety shall establish emergency 



134 



100 SENATE — No. 2023 [August 

evacuation time estimates and traffic control plans based on 
evacuations of people within the EPZ to reception centers at least 30 
miles from the reactor and should anticipate secondary or shadow 
evacuations. 

The Division of Nuclear Facility Safety shall commission a site- 
specific probabilistic risk analysis of severe accident probabilities at 
Pilgrim and the consequences of radioactive releases and the probable 
health effects at various distances from the plant. 

Major operations specified in the Plan and agency responsibilities 
are outlined in Recommendation VI. 

2) Monitoring. 

The committee recommends that the Division of Nuclear Facility 
Safety and the Department of Public Health adopt and develop a 
Remote Monitoring System (RMS) which shall incorporate three 
major components: gross gamma detectors radially positioned around 
each nuclear power station; an automated, isotopic gaseous effluent 
monitor system which samples from major engineering release points; 
and a reactor parameter data communication link to each facilities' 
on-site computer. In addition there shall be provided liquid effluent 
monitors, which will be located at each plant's liquid discharge points. 
All of these RMS components shall be connected through a dedicated 
data communications link to provide instantaneous readings to the 
Division of Nuclear Facility Safety Headquarters. Technical staff 
shall review the data and perform analyses of plant conditions. 

a) ENVIRONMENTAL RADIATION MONITORING SYS- 
TEM: The Division of Nuclear Facility Safety shall develop a dual 
ring system of environmental radiation monitors utilizing gross 
gamma detectors and automated isotopic detectors which shall be 
installed and maintained around each reactor site that would measure 
a change in radiation levels resulting from a radioactive release at the 
reactor site. This system shall serve a multitude of purposes. It shall 
define the existence of a radioactive release sufficiently large enough 
to impact upon the environment, as well as detect a release through 
an unmonitored release path. In addition, the system shall provide 
a backup capability should the effluent monitoring system be 
inoperable, and shall also help reveal the presence of atmospheric 
conditions (windshear) which could result in plume dispersal not 
following anticipated direction of travel. 

The Environmental Radiation Monitoring System shall be 



135 



1987] SENATE - No. 2023 101 

developed to provide the following features: (1) up to 16 monitors 
per site (1 detector for each 22.5 degree segment) at a distance of 
approximately 2 miles from the reactor site; (2) minimum detection 
level of 1 microRoentgen per hour (natural background levels are 
approximately 7 to 10 micro Roentgens per hour); (3) maximum 
detection limit is at least 10 Roentgens per hour (one million times 
normal background levels); (4) automatic transmission of radiation 
readings to the Nuclear Facility Safety Division headquarters 
computer system every 8 minutes; and (5) transmission of alarm 
signals to the Nuclear Facility Safety Division headquarters in the 
event of high radiation levels or failure of environmental monitoring 
system components. 

b) REACTOR PARAMETER DATA LINK: The Massachusetts 
Division of Nuclear Facility Safety shall install a direct data 
communication link between the Division headquarters computer and 
each nuclear reactor's control room computer for the monitoring of 
the Commonwealth's two nuclear power reactors and their safety 
systems. This data link shall be developed for early notification of 
events that could lead to nuclear accidents. This system is an essential 
element in providing continuous plant safety assessment, early 
detection of abnormal conditions, and evaluation of nuclear plant 
transients. 

The system signals to be received at the Division's headquarters 
shall be the same signals available to the nuclear plant personnel on- 
site. The Division shall select particular parameters to be transmitted 
to them from an index containing all available plant system 
information. Parameters selected by the Department provide detailed 
information on the operation characteristics of all essential plant 
safety systems. 

Some major features that are available that may be included in this 
system are: (1) 1,000 to 1,300 parameters (signals) per reactor 
accessible for transmission every two minutes; (2) technical 
parameters include: reactor power levels, reactor water levels, steam 
generator water levels, containment temperatures, engineered safety 
system availability, and essential pump flow rates; and (3) system 
software for displaying either current or historical signals. 

c) THE RADIOACTIVE GASEOUS EFFLUENT MONITOR- 
ING SYSTEM: The Division of Nuclear Facility Safety and the 
Department of Public Health shall be directed to utilize and 



136 



102 SENATE - No. 2023 [August 

implement a custom designed automated system to monitor gases 
routinely released by nuclear power plants. The Radioactive Gaseous 
Monitoring System is designed to identify and quantify the 
radioactive components of the gaseous discharges from each stack and 
other gaseous release points to the environment and transmit the 
information immediately to the Division so that appropriate 
emergency action can be directed in the event of a nuclear accident. 

The Radioactive Gaseous Effluent Monitoring System is a state of 
the art, computerized system which continuously transmits data from 
the nuclear power plant to the Division's headquarter computer. 

This system includes the following features: (1) dedicated computer 
at the power plant sites for operation and analysis; (2) minimum 
detection level of 10 to 13 microCuries/ cubic centimeter; (3) 
maximum accident detection limit of 10 microCuries/cubic 
centimeter; (4) collection and analyses of radiation in three forms: 
iodines, particulates, and noble gases; (5) automatic background level 
checks; (6) automatic check on source verifications; (7) remote 
computer access to determine operational status and data; (8) signal 
alarms in the event of high radiation levels or failure of a system 
function; (9) detection of specific isotopes based on radiation energy; 
and (10) accelerated operation rates designed to maximize data 
collection during an accident. 

d) EMISSION STANDARDS: It is essential that Massachusetts 
Public Health Officials review and determine the maximum 
permissible levels of airborne radioactive emissions from nuclear 
power plants that do not threaten the public health and safety. By 
adopting state emission standards as authorized by the Clean Air Act 
amendments of 1977, the Commonwealth will ensure that safe 
standards are in place and strictly enforced. Until such standards are 
set by the Department of Public Health, the federal standards should 
be adopted as state standards so that the state officials immediately 
have the power to inspect onsite and off-site monitoring equipment 
and have independent enforcement authority over emissions. The 
state shall assess all licensees for the cost of setting up a monitoring 
system for the Commonwealth. 

Perhaps the most important safety function of a monitoring system 
is to assist emergency response officials in determining the extent of 
a serious accident and the amount and direction of radiation releases. 
We recommend installation of a comprehensive and sophisticated new 



137 



1987] SENATE - No. 2023 103 

monitoring system similar to the one that is already installed and 
functioning in Illinois to provide substantially more public protection. 

3) Possible Adverse Health Effects From Pilgrim Radioactive 
Emissions 

a) Radiation exposure can cause cancer, birth defects and 
chromosomal damage. The Department of Public Health has 
determined that there has been a significant increase in leukemia cases 
in the area surrounding Pilgrim, although the department is still 
studying what the cause of those leukemias may be. 

b) The Special Committee recommends that four health studies be 
conducted: 

1) A follow-up study on the leukemia cases in the Plymouth area 
to determine what environmental or occupational exposures may 
have caused those leukemias. 

2) A study to test the theory that coastal winds may concentrate 
the radioactive emissions from the Pilgrim plant in such a way 
as to cause adverse health consequences in coastal areas. 

3) A regional study of adverse health impacts, including leukemia 
incidences, birth defects and infant mortality, downwind from 
other nuclear reactors in New England. 

4) A health study of all past and present Pilgrim employees to 
determine the adverse effects, if any, of exposure to radiation 
from Pilgrim. 

4) The cost of the Division of Nuclear Facility Safety and the 
Department of Public Health's monitoring system should not 
be borne by all taxpayers but by the utility ratepayers through 
an assessment of the nuclear plant licensees. 



138 

104 SENATE - No. 2023 [August 

RECOMMENDATION II 



ENDORSEMENT OF COMPREHENSIVE LOAD 
MANAGEMENT AND CONSERVATION PROGRAMS 

The special committee investigating the Pilgrim Nuclear Generating 
Facility reviewed testimony involving energy supply, load 
management and conservation measures during several hearings. The 
committee concluded that in order to meet current and future power 
supply demands all utilities in the Commonwealth must implement 
stringent load management and conservation programming. The 
committee stresses that authority should be given to the Department 
of Public Utilities to oversee the implementation of aggressive load 
management and conservation programs for any electric utility relying 
on the continual operation of the Pilgrim Generating Facility. 

Load Management 

The committee endorses the concepts contained in the Final Report 
of the Boston Edison Review Panel as they relate to increased load 
management programs by Boston Edison Company. The committee 
recommends that the Department of Public Utihties (DPU) be 
required to encourage and assist Boston Edison in implementing the 
specific load management programs. The DPU shall also be required 
to encourage and assist Commonwealth Electric Company in 
implementing appropriate cost-effective load management programs 
that offer the company similar energy-saving results. 

Boston Edison Company should identify and fund effective "load 
management" measures, such as radio-controlled water heaters and 
nighttime water chilling systems, which reduce peak energy use and 
are cheaper than the cost of producing electricity from new power 
plants. In addition, the utility should provide incentives for 
commercial and industrial sector customers to form "load-shedding 
cooperatives," where a group of participants agrees to share minimal 
energy use reductions during peak demand emergencies. 



139 

1987] SENATE - No. 2023 105 

Conservation 

The special committee endorses the concepts contained in the Final 
Report of the Boston Edison Review Panel as they relate to increased, 
cost-effective conservation programs by Boston Edison Company. 
The DPU should be required to encourage and assist Boston Edison 
in implementing the specific conservation programs. The DPU shall 
also be required to encourage and assist Commonwealth Electric 
Company in implementing appropriate, cost-effective conservation 
programs that offer the company similar energy-saving results. The 
DPU should direct all utilities to make significant investments in 
energy conservation and energy efficiency programs, known as 
"demand-side management" programs, to reduce the energy demand 
of all utilities' customers. The DPU should set target investment levels 
and participate in the design of demand-side management programs. 
Such programs should include, but not be limited to the following, 
where shown to be cost effective: 

1) The special committee recommends all utilities should employ 
d.esign teams to go into buildings that use large quantities of 
electricity to identify the full package of demand-side 
management measures and practices that are cheaper than the 
utilities commensurate cost of producing electricity from new 
power plants over the useful life of the conservation measures. 
The utility should then fund the purchase and installation of 
identified cost-effective measures. 

2) All electric utility companies should offer their customers 
incentives for a wide range of efficiency measures. This incentive 
program should go far beyond the limited scope of current and 
prior utility rebate programs for refrigerators and efficient lights. 

3) All electric utility companies should also provide incentives for 
electrical energy efficiency in new construction including hook- 
up fee and penalties. 

4) All electric utility companies should convene an auction for 
energy efficiency improvements similar to the bidding process 
that is currently being used to promote the development of small 
power and co-generation facilities. 



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106 SENATE - No. 2023 [August 

5) The committee recommends that the DPU should be allowed 
to provide all utilities with a profit, or "rate of return" on the 
investment the company makes in demand-side management 
programs. This rate of return, to be recovered from the 
company's ratepayers, could be at least as high and/ or up to two 
percentage points higher than the rate the utilities are authorized 
to receive for capital investments in new power plants. 



141 

1987] SENATE - No. 2023 107 

RECOMMENDATION III 



PRIORITIZE MASSACHUSETTS BASED ELECTRICAL 
GENERATING FACILITIES 

I. The Committee recommends that the Energy Facilities Siting 
Council and the Department of Public Utilities give priority 
consideration to the construction of non-nuclear electric generating 
plants located within the Commonwealth when reviewing the plans 
of any electric utility for the construction of a new generating plant. 

The Massachusetts General Laws and regulations promulgated by 
regulatory agencies require utility companies to provide ratepayers 
with electricity at the lowest possible economic cost and with the least 
possible environmental impact. In planning to meet the electrical 
energy needs of ratepayers, the Department of Public Utilities, the 
Energy Facilities Siting Council, and the utilities should consider and 
evaluate the following factors: 

1) The full "life cycle" economic costs of each energy resource 
option. These include costs for construction, financing, 
operation and maintenance, and decommissioning. With respect 
to energy efficiency and load management programs, costs for 
materials and installation and program administration should 
be considered. 

2) The full environmental costs of each energy resource option. 
Environmental impacts associated with the siting of facilities, 
degradation of outdoor and indoor air quality, potentially 
adverse impacts on water quality, and risks to public health 
should all be fully considered when deciding which energy option 
to pursue. 

3) The number of jobs created by the use of each energy resource 
option. The number of long- and short-term jobs that are directly 
and indirectly created as a result of developing various energy 
resource options should be considered and compared. Other 
state and local economic development costs and benefits, such 
as support of indigenous industry and inflows or outflows of 



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108 SENATE - No. 2023 [August 

capital resulting from development of each energy resource 
option should also be considered. 

4) The reliability of the energy resource option. Massachusetts 
needs affordable and reliable energy resources to help sustain 
a healthy economy. Energy resource options that decentralize 
and diversify the region's fuel mix, and which reduce reliance 
on non-indigeous fuels, should be prioritized. 

All potential resource options — including energy efficiency 
improvements and practices, load management measures and 
practices, small power production, co-generation, and small and large 
oil, natural gas and clean coal technologies should be evaluated and 
compared using the above criteria. 

The Committee believes that priority should be given to 
Massachusetts based plants. The Committee is concerned about the 
increased dependence on plants located outside Massachusetts for our 
electric generating needs. It believes that this trend increases the 
likelihood of supply disruptions, thereby complicating unduly our 
ability to forecast long range supply. This trend of reliance on plants 
outside Massachusetts is also detrimental to our economy, since it 
creates jobs in other states that would otherwise benefit Massachusetts 
workers. 



143 

1987] SENATE - No. 2023 109 

RECOMMENDATION IV 

DEPARTMENT OF PUBLIC UTILITIES TO ESTABLISH A 

FIVE-YEAR SUPPLY PLAN WITHOUT RELIANCE ON 

THE PILGRIM PLANT 

The Committee has found that the Pilgrim Nuclear Generating 
Facility at Plymouth, Massachusetts has suffered from serious and 
continuous mismanagement. Although significant efforts are being 
made by its owners to rectify the management problems, considerable 
uncertainty remains over the reUability of the plant to contribute to 
the electric supply needs of the Commonwealth. 

The Committee therefore recommends that the Department of 
Public Utilities (DPU) establish a five-year plan for ensuring adequate 
supply without consideration of the electrical production of Pilgrim 
plant. Due to the uncertain future of Pilgrim, the DPU should 
establish a supply plan for the Commonwealth that does not require 
any dependence on the Pilgrim plant. Such plan shall include a 
forecast of future supply and demand which delineates each source 
of power and its location. January 1, 1988 is the due date for the 
implementation of the initial five-year plan. 

The Committee recommends that in determining whether to restart 
the Pilgrim Nuclear Power Plant, the availability of sufficient cost 
effective and safe alternate energy resources shall be taken into 
consideration. 



144 

110 SENATE — No. 2023 [August 

RECOMMENDATION V 



COMMITTEE REVIEW OF THE NUCLEAR REGULATORY 
COMMISSION (NRC) SYSTEMATIC ASSESSMENT OF 

LICENSEE PERFORMANCE REPORT (SALP) AND 

RECOMMENDED MEASURES TO CORRECT SERIOUS 

FUNCTIONAL DEFICIENCIES AT THE PILGRIM NUCLEAR 

GENERATING FACILITY AT PLYMOUTH 



The Pilgrim nuclear power plant has a well documented, and well 
publicized, history of problems. This history has called into question 
both the level of safety when Pilgrim is operating and Boston Edison's 
ability to run the plant. With an issue as emotional as nuclear power, 
the loss of public confidence must be addressed in addition to the 
actual safety problems. 

Massachusetts, particularly residents of Southeastern Massachu- 
setts, have every right to demand that Pilgrim be one of the best run 
plants in the country rather than one of the worst. Clearly the initiative 
for this belongs to Boston Edison. Pilgrim has been "off-line" for more 
than a year. During that time the utility has undertaken significant 
initiatives to improve its performance. In some cases they have taken 
a lead in the nuclear industry to address certain problems. More work 
remains to be done, however, and how effective the company is in 
its work will have to be judged when it is completed. 

This is neither a "pro-nuclear" nor an "anti-nuclear" report. The 
committee feels that where there are problems, they must be 
addressed, prior to restart, and that the plant should not operate until 
all major deficiencies are corrected. Individual members will have 
their own views on nuclear power but everyone agreed that the 
overriding issue here was not to resolve the nuclear debate but to 
address the problems of one particular plant. 

The committee heard testimony on specific operations and plant 
problems from Boston Edison, the Nuclear Regulatory Commission, 
and representatives from citizen groups. In addition, the committee 
has had access to Public Safety Secretary Charles Barry's report to 
the Governor on the plant and volumes of NRC reports. 



145 



1987] SENATE - No. 2023 111 

To try and identify every single problem and the appropriate 
solutions would be beyond the committee's capability and 
jurisdiction. The sheer number of technical matters, the lack of expert 
staff, and the debate within scientific and regulatory circles over some 
issues made it unrealistic for us to devise the specific solutions to many 
particular problems. Likewise, it makes little sense to list every specific 
problem since it would make more difficult our aim to focus public 
attention on the most substantive problems. 

The committee does feel, though, that it is useful for the Legislature 
to summarize the patterns of problems and our perceptions of the 
work which needs to be done. This, we hope, will not only focus 
greater attention on the major problems but also give the Legislature 
and the public some standard by which we can measure Edison's 
progress. 

The NRC, on many occasions, has claimed it will force Edison to 
prove significant improvements before restart is allowed. As part of 
their process they will develop a detailed check list of matters requiring 
solutions. The committee urges the NRC to include our concerns as 
part of that process. If addressed, we feel plant safety will be enhanced 
and public confidence raised. 

The Nuclear Regulatory Commission recently issued the Pilgrim 
Systematic Assessment of Licensee Performance (SALP) for the 15- 
month period of November 1, 1985 through January 31, 1987. SALP 
is a comprehensive assessment of the plant analyzed into twelve 
functional areas. The report identifies recurring programmatic 
weaknesses in five functional areas including: radiological controls; 
surveillance; fire protection; security; and assurance of quality. 

These five functional areas received low SALP grades of 3. The 
NRC rates on a 1,2, and 3 basis and defines a 3, the lowest rating, 
as follows: 

"Both NRC and licensee attention should be increased. 
Licensee management attention or involvement is acceptable 
and considered nuclear safety, but weaknesses are evident; 
licensee resources appear to be strained or not effectively used 
so that minimally satisfactory performance with respect to 
operational safety is being achieved." 
The following is an outline of the problems in each of the five 
functional areas as reported by the NRC, followed by the committee's 
recommendations. 



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112 SENATE — No. 2023 [August 

(1) RADIOLOGICAL CONTROL: "This assessment covers 
radiation protection, effluent monitoring and controls, 
radwaste shipping and environmental monitoring. SALP 
found that the licensee made numerous improvements in the 
overall quality of the radiological controls program. However, 
implementation of the program continues to be weak. When 
problems with program implementation or adequacy are 
identified, corrective actions are sometimes not adequate or not 
implemented resulting in the need for further NRC involve- 
ment. In the area of effluent monitoring and control, the 
licensee implemented the new effluent technical specifications 
in a generally acceptable manner, however, failure to take 
action on significant long standing deficiencies in the 
environmental Thermolumenescent Dosimeters (TLD) 
program detracted from the good effort." 

COMMITTEE RECOMMENDATIONS: 

a) — Aggressively supervise the radiological control program. 

b) — Establish and implement measures to verify program imple- 

mentation and implement corrective actions for deficiencies. 

c) — Interactions with personnel outside the radiological group 

should be significantly strengthened. 

d) — Continued clean up of plant and reduction of contaminated 

areas. 

e) — Strengthen the role and company jurisdiction of radiation 

control department over the other departments. 

f) — Exposure histories of past and present employees and con- 

tracted workers be compiled, continually updated, and 
reported to DPH and Nuclear Facility Safety Division. 

g) — Improve programs for replacement of thermoluminescent 

dosimeters. 

h) — Improve training of employees in radiological environmental 
technical specifications. 

i) — Improve control and accounting of special nuclear material 
under one gram. 

j) — Improved access control to high radiation areas. 

k) — Improved inspection of vehicles leaving site for any con- 
tamination. 



147 



1987] SENATE - No. 2023 113 

(2) SURVEILLANCE: "Individual surveillance tests were well 
conducted and controlled. The response to recurring local leak 
rate test failures was also positive. However, the licensee has 
been slow to recognize and correct weaknesses in the control 
of the program tests. This lack of progress is reflected in the 
large number of surveillance-related licensee event reports and 
NRC violations issued during the current period. The control 
of the program is fragmented and not always effective and 
appears to depend more on historical past practice then in a 
well-founded, systematic approach. This is a major weakness 
that must be corrected. The licensee's measuring and test 
equipment control program also need improvement." 

COMMITTEE RECOMMENDATIONS: 

a) — Significant site and corporate management attention is needed 

to correct deficiencies in this area, 
b) — Place a single qualified individual in overall charge of the 

surveillance program. 

(3) FIRE PROTECTION: "The licensee has been slow to 
strengthen the fire protection program. Problems included 
inadequate surveillance procedures, degraded fire barriers, 
inoperable fire protection system equipment, and poor quality 
fire brigade training. Although action has been taken to address 
these concerns the program has suffered from a chronic lack 
of attention and should be closely monitored." 

COMMITTEE RECOMMENDATIONS: 

a) — Significantly reduce the amount of inoperable fire protection 

equipment in the station, 
b) — System for assessing priority needs and timely correction of any 

deficiencies in fire barriers and protection equipment, 
c) — Improved supervision and training of fire watchers, 
d) — Provision for independent water and power supplies, 
e) — Completion of all Appendix R improvements, 
f) — System to control combustible material on-site. 

(4) SECURITY AND SAFEGUARDS: "The previous SALP 
report identified serious NRC concerns regarding the licensee's 



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114 SENATE — No. 2023 [August 

awareness of, and attention to, NRC physical security 
objectives and the need for additional management attention 
to, and support of, the security program to insure that the 
program was properly implemented. The previous SALP 
report also identified NRC's belief that the licensee had initiated 
actions to resolve those concerns and that the security program 
was receiving increased management attention. However, 
shortly after the beginning of this assessment period, it became 
apparent to the NRC that, due to the number and complexity 
of the identified problems and some other problems which were 
then surfaced, far more extensive management attention and 
resources would be required. As evidenced during this 
assessment period, the need for additional attention and 
resources by the licensee continued until late in this assessment 
period. As a result, little physical progress toward improving 
the program was accomplished by the licensee during the 
period." 

COMMITTEE RECOMMENDATIONS: 

a) — High level corporate and site management attention to the 
recently established priority level for the security program 
upgrade should continue in order to implement commitments 
and develop an effective program. 

b) — NRC/ Boston Edison review of relationship of contracted 
security force over Boston Edison and other contracted 
employees. Does Security have adequate power to control 
plant personnel and question employee activities? 

c) — Develop and implement effective program to eliminate any 
presence or use of alcohol and drugs. 

d) — Elimination of any violations or weaknesses in security 
barriers. 

(5) ASSURANCE OF QUALITY: "Although the licensee has 
exhibited good performance in certain activities such as outage 
control and engineering and has displayed initiative in its safety 
enhancement program, significant deficiencies still were found 
to exist in radiological controls, surveillance, fire protection 
and security. Some of these deficiencies have existed 



149 



1987] SENATE - No. 2023 115 

throughout the period and have been identified in previous 
SALP reviews, and by the Hcensee's own quahty assurance 
organization. The ambiguity of the site organizational structure 
and the instabihty in the corporate and site management team 
have resulted in the licensee's inability to address and resolve 
these long-standing problems without repeated prompting and 
overview by NRC. Senior corporate management was slow in 
confronting the problems and in implementing corrective 
actions. Late in this assessment period and immediately 
following it, the licensee took steps to address its organization 
weaknesses. However, the effectiveness of these efforts in 
improving the licensee's performance remains a matter of 
continuing NRC interest and concern." 

COMMITTEE RECOMMENDATIONS: 

a) — Continue senior management attention to identify problems to 

ensure that they are promptly and effectively resolved, 
b) — Improve tests and surveillance of equipment program, 
c) — Greater authority of quality control staff over other 

departments to resolve any conflicts between procedures and 

personnel in different operation groups, 
d) — Improve training and supervision over contract workers, 
e) — Improvements in visual surveillance system to properly identify 

and describe deficiencies, 
f) — Improve training, testing and requalification of personnel. 

(6) PLANT/ EQUIPMENT 

COMMITTEE RECOMMENDATIONS: 

a) — Maintenance requests back log be eliminated. 

b) — Complete review of maintenance and testing schedules with all 

incomplete testing being finished and any deficiencies 

corrected, 
c) — Identification and repair of Main Stream Isolation Valve and 

RHR pumps which caused initial spurious scram which closed 

the plant, 
d) — NRC investigation and public explanation of recent reports of 

deficiencies in certain General Electric reactors, including 

Pilgrim. The public should be informed of the possible 



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116 SENATE - No. 2023 [August 

problems and any action taken by General Electric or Boston 
Edison which has corrected these deficiencies. All uncorrected 
problems should be corrected, 
e)^ — The NRC and General Electric should also make available to 
the public the General Electric report. 

(7) GENERAL MANAGEMENT CONCERNS: The following are 
recommendations which address general management areas 
which the committee feels need review. 

COMMITTEE RECOMMENDATIONS: 

a) — Staff vacancies in key areas should be filled to adequate levels, 
b) — Demonstration that the new programs, divisions and personnel 

can actually perform as planned, 
c) — Resolution of inter-group conflicts and clearer lines of 

authority for safety, ALARA (As low as reasonably 

achievable), and fire protection personnel over other divisions, 
d) — Review and planning of transition from outage and 

maintenance mode to on-line operation so that they are 

prepared if restart is approved. 

(8) REACTOR CONTAINMENT: In its most recent SALP report 
the NRC noted the following: "Plant hardware changes were 
also impressive, particularly the planned Mark I containment 
enhancements. The modifications go considerably beyond NRC 
recommendations and show a concern for nuclear safety." 
Nevertheless, serious concerns have been raised, both inside and 
outside of the NRC, about the Mark I containment and its 
possible failure in the event of a major accident. The Committee 
has sent a letter to Boston Edison seeking more information on 
exactly what work is planned to enhance the containment 
system. In addition, the committee strongly urges that prior to 
restart the NRC, the state, and Boston Edison shall hold a public 
hearing on: 

a) The possible defects or weaknesses of the Mark I containment; 

b) the work planned by Boston Edison to improve it; 

c) the schedule for that work; 

d) NRC studies and others done on the integrity or possible failure 
of the containment in the event of a major accident. The 
containment is such a crucial safety feature in nuclear plants that 



151 



1987] SENATE - No. 2023 117 

all work to strengthen any weaknesses must be completed prior 
to restart, 
e) An evaluation of any additional safety features such as filtered 
venting of the containment, molten core barriers, underground 
residual heat removal system, and a secondary steel containment. 

(9) STANDBY GAS TREATMENT SYSTEM: Prior to refueling 
the problems identified with the Standby Gas Treatment System 
should be corrected, 
(10) DECOMMISSIONING PLAN: It is unclear what happens to 
the plant and storage of radioactive waste when the plant is 
permanently closed. The questions of the cost involved 
decommissioning, the impact on Plymouth taxes, waste storage, 
security, and dismantling or "seaUng" of the reactor building are 
of great concern to area residents. The NRC, the state and Boston 
Edison should develop decommissioning plans, well before a 
scheduled closing, to answer these and other questions. 

The Committee after intensive review of the NRC SALP report 
recommends the Boston Edison Company immediately take positive 
action on all of the above recommendations. Boston Edison should 
improve all of the categories which received grades of category 3 on 
the most recent SALP report. The two primary causes for the NRC's 
category 3 findings were slowness in making improvements and lack 
of management attention. These problems should be resolved so that 
none of the functional areas maintains a category 3 grade. It is 
imperative that all improvements are completed before action is taken 
to restart the Pilgrim Nuclear Power generating facility at Plymouth. 



152 

118 SENATE - No. 2023 [August 

RECOMMENDATION VI 

IMPROVED EMERGENCY PREPAREDNESS PLANNING 

Emergency preparedness is the last layer of protection for public 
health and safety in the event of an accident at a nuclear plant. Until 
recently, emergency planning seems to have been perceived more as 
a regulatory requirement than a form of protection which might be 
called into use. As public concern over nuclear plants has increased 
over the past year, so has emergency planning come under greater 
scrutiny. 

This scrutiny has found the obvious current emergency planning 
is inadequate. The primary responsibility to correct these inadequacies 
rests with the state. Working with federal officials, local officials, and 
the utility the state must take immediate action to develop plans that 
are more realistic and dependable. 

The federal government has reserved to itself most powers dealing 
with nuclear power plants. The state, however, is left with almost total 
responsibility in protecting the public should an accident ever happen. 
While this may be jurisdictionally awkward there is no substitute for 
state and local planning. Local and state officials are the most 
qualified to prepare and implement emergency plans. 

It is unacceptable to this committee for a private utility or federal 
agency to try and fulfill or usurp state and local responsibility. The 
committee feels that prior to restart emergency plans must first be 
reviewed and approved by town officials, in the Emergency Planning 
Zone (EPZ) communities, and by the state. Nuclear Regulatory 
Commission (NRC), Federal Emergency Management Agency 
(FEMA), Boston Edison, the State, and towns should work on a 
schedule to coordinate the review and decision on whether to approve, 
prior to restart. 

There is growing debate over how far states can use the planning 
approval requirement as a means of preventing a new plant from being 
licensed or of closing a licensed plant, if a state does not believe an 
emergency response plan can adequately protect the public health and 
safety. It appears that the NRC, Congress, and undoubtedly the courts 
will be reviewing this issue as more states withhold approvals. 

The state should pursue two courses. State and local governments 
should develop the strongest possible emergency plans. The public's 



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1987] SENATE - No. 2023 119 

health and safety demands nothing less. If, after those plans are 
developed, the Governor feels they are still inadequate then he may 
withhold approval. 

The committee heard testimony from the Department of Public 
Safety about the need to plan beyond a set limit of ten miles. The 
Department stressed, though, that with deficiencies in current ten mile 
planning any work beyond the ten mile zone should not deflect any 
attention from the communities within the zone. Communities closest 
to the plant require a higher level of planning than communities 
farther away. The Department also testified that while Civil Defense 
is the primary agency for dealing with emergencies other divisions are 
involved such as the National Guard, Public Safety, and Public 
Health. The Department noted that coordination between state 
agencies for nuclear emergency planning needs to be improved. 

Local Civil Defense officials from several towns in the EPZ testified 
before the committee. Their concerns included: 

A) Lack of a reception/ decontamination area; 

B) A need for greater technical and material assistance from the 
state and utility; 

C) Criticism that the plans lacked specific written agreements with 
parties which might be involved with an emergency, such as bus 
companies and hospitals; 

D) A need to plan for regional school systems in which students 
come from one but not all towns within the EPZ; and 

E) The need for more inter-community planning in order to have 
a coordinated regional plan. 

The town of Plymouth has created its own local advisory committee 
on nuclear matters. That committee has thoroughly reviewed the 
town's emergency response plan. Their report has been made available 
to the committee and demonstrates the kind of detailed planning 
necessary for a strong response plan. It also demonstrates the 
indispensable role of local governments in developing plans. Many 
of their recommendations would be helpful to other towns. Their 
report is included (see Appendix 9). 



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120 SENATE - No. 2023 [August 

While primary responsibility for planning rests with state and local 
officials there is necessary assistance which should come from the 
utility. This includes technical advice as well as material support 
accepted by the state, a county, or a town. The committee feels that 
this assistance should be paid for through utility assessments which 
will be passed on to utility ratepayers rather than all taxpayers. 

Specific improvements to the emergency plans need to come from 
the utility, towns and state. The committee recommends the following 
improvements: 

BOSTON EDISON PLANNING ASSISTANCE: 

(1) Boston Edison Company should provide updated and accurate 
Evacuation Time Estimates under a wide variety of accident 
scenarios. This will enable state and local officials to better plan 
traffic management in the event of an emergency. 

(2) Identification, notification and workable evacuation plans for 
mobility impaired and individuals who will have difficulty being 
notified of an emergency or in being familiar with the emergency 
response procedure. Such individuals include the physically 
disabled, those depending on public transportation, the hard 
of hearing and those who speak limited English. Greater 
attention to these individuals will help ensure that no one is 
excluded from the planning. 

BOSTON EDISON EQUIPMENT: 

(1) Boston Edison should improve Public Alert Systems including 
testing. Sirens should be tested more frequently with improved 
monitoring and identification of individual siren deficiencies. 
Siren systems should be audible in the entire EPZ, and loud 
enough to be heard in buildings with closed windows. In 
addition, this system should be supplemented with an adequate 
number of loudspeaker equipped vehicles. 

(2) Review and supply of needed equipment for shelters and 
reception areas for evacuations. During summer months local 
population swells, increasing the need for sheltering areas for 
non-resident visitors. 



155 



1987] SENATE - No. 2023 121 

(3) Provide greater information in the event of an emergency. 
During an incident, people may not have written information 
on hand about procedures to be followed. This- is particularly 
true for non-residents. Printed material with procedures for an 
emergency should be pre-printed for quick distribution in group 
shelters, relocation areas, hospitals, public transportation, and 
through school children during an emergency. 

(4) Boston Edison should update the Nuclear Energy Pamphlet to 
impress upon the public the importance of following official 
instructions. Necessary information should include maps, 
location of public shelters, locations of public transportation 
facilities, Emergency Broadcast System affiliates, traffic routes, 
reception areas and personal safety precautions. 

EMERGENCY PLANNING ZONE (EPZ): 

(1) Clarify that when any part of a town lies within an EPZ, the 
entire town shall be part of the EPZ. Planning and resources 
for these towns will have to be upgraded. 

(2) Clarify planning for regional schools which have students from 
at least one, but not all, towns in the school system which are 
part of an EPZ. 

(3) Clarify authority of Public Safety to plan for a radiological 
emergency beyond a 10 mile EPZ. (See Recommendation I — 
Division of Nuclear Facility Safety) 

(4) Evacuation time estimates and traffic control plans should be 
based on evacuations of people within the EPZ to centers well 
beyond the 10 mile zone and should anticipate secondary or 
shadow evacuations. 

STATE PLANNING: 

(1) Increase state assistance to local planners. This should include 
technical assistance as well as financial assistance for local use. 
The goal should be coordinated regional planning as well as 
strengthened local plans. 



156 

122 SENATE - No. 2023 [August 

(2) Inventory and where necessary create adequate local shelters 
to protect non-resident visitors in the event of emergencies 
which may not require e-vacuation. 

(3) Identify area medical services, hospitals and medical personnel 
available for use outside of the EPZs. Also evaluate any 
additional services and supplies which may be necessary to serve 
EPZ population in the event of an emergency, including 
emergency treatment facilities and training of medical 
personnel. 

(4) The state and towns should participate in appropriate 
emergency drills. 

(5) Specific planning shall be developed for emergency notification, 
evacuation planning, and traffic control planning should be 
imposed in areas outside of an EPZ which pose unique 
problems, e.g.: Cape Code and the Islands. 

(6) Inventory of available buses, ambulances and handicapped/ 
elderly vans, to assist in an evacuation. Develop an inventory 
of service stations and towing operations to be available along 
evacuation routes. 

(7) Supervise planning by towns, ensure a coordinated, regional 
plan, and ensure cooperation between the utilities and area 
towns. 

(8) Identify and designate adequate reception and decontamination 
centers and ensure the availability of adequate supplies and 
equipment. 

(9) Ensure appropriate annual review and publication of plans 
working with the utilities, towns and Federal Emergency 
Management Agency (FEMA). 

(10) Evaluate and where necessary correct effectiveness of 
notification and communication system between state and local 
officials. 



157 



1987] SENATE - No. 2023 123 

(11) Identification, notification and workable evacuation plans for 
people in all institutional facilities — such as hospitals, nursing 
homes, schools and prisons — inside the EPZ. 

(12) Contractual agreements for the above services where 
appropriate should be made to avoid any erroneous 
assumptions of transportation in the event of an evacuation. 

LOCAL PLANNING: 

(1) Each town in an EPZ should consider establishing a 
Radiological Emergency Response Plan Committee to review 
matters pertaining to emergency response planning. 

(2) Local plans need more thorough documentation and letters of 
agreement between involved parties to ensure clear lines of 
responsibilities in the event of an emergency. 

(3) Local officials should inventory local planning needs, 
equipment and resources which can be provided by the 
Division of Nuclear Facility Safety or the utilities. 

(4) In addition to plans for their own communities, local officials 
should work closely with neighboring communities to ensure 
workable regional planning. 

(5) Each town in an EPZ should establish plans for informing non- 
residents of procedures to be followed in the event of an 
emergency. 

The state and utility have been ineffectual and too informal in 
developing adequate emergency response plans. The committee, 
therefore, finds: 

A) The Pilgrim Nuclear Power Plant should not restart until, and 
unless, an emergency preparedness plan, including evacuation, 
has been approved by the Selectmen in the EPZ communities 
and by the Governor; 



158 



124 SENATE - No. 2023 [August 

B) Federal, state, and local officials and the utility should 
coordinate actions in order to reach a decision on whether to 
approve emergency response plans prior to restart. 

C) The cost of emergency planning should not be borne by all 
taxpayers, but financed through utility assessments. 



159 

Mr. FoRMAN. I, frankly, don't see the problem with giving the 
States the power to decide whether or not they have nuclear power 
plants. I fully understand and accept the rationale that States and 
local governments shouldn't necessarily regulate nuclear power 
plants in monitoring them in terms of their operation as well as in 
terms of the conditions of health effects. But I have a problem with 
the federal government prohibiting States from deciding whether 
or not they want plants in their State. 

I'm also troubled by the fact that the only straw that we seem to 
be grabbing at in trying to create some State authority is the use of 
emergency preparedness and withdrawal of State approval or 
denial of State approval for emergency plans. I think that actually 
could lead to some public safety risks, depending on how the court 
and the NRC interpret the State authority. So I would urge Con- 
gress and the administration to consider some outright approval to 
States across the country, not just because of Pilgrim, but in terms 
of State authority and Federal. 

The Chairman. What do we do on nuclear waste? Do we give the 
States authority to reject that? 

Mr. Form AN. We keep the pressure on Congress and the adminis- 
tration to pick a site out in Nevada. [Laughter.] 

The Chairman. Do we give those States the power to reject? 

Mr. Forman. I don't think we can. 

The Chairman. First of all, we might just make it normal proce- 
dure if a State is going to use nuclear power, let them take the risk 
in terms of storing it. 

[Applause.] 

Mr. Forman. If I can suggest something in response to that. We 
deal with issues in this State over low level waste, solid waste and 
we run into those siting problems. I think that you can clearly 
infer a distinction between the State's willingness or desire to have 
an operating plant sited in their State as opposed to national 
public health interest of finding a disposal site which is en\dron- 
mentally sound. 

The Chairman. I think that's right. 

Mr. Alexander. I would say, first of all, that the legal issue of 
the State's problem is still up in the air. You know Governor Ce- 
leste of Ohio actually withdrew the Emergency Response Plan for 
nuclear powerplants there until the Commission could take an- 
other look at it, and that's in the court as to whether or not he has 
that authority or not. 

So I would first say that it is still unclear whether Massachusetts 
can say, "Well, we're not going to allow Pilgrim to operate because 
we don't feel that the emergency response plan is adequate," but I 
do think it would be worthwhile to allow Congress to allow States 
the ability to regulate nuclear power to the extent that if Congress 
has a standard, that States should be allowed to have standards 
that are at least as tough as those of the Federal standards; that 
way you are not going to have people who might not be as expert 
weakening the standards. On the other hand, if the States should 
have proper standards, it should be allowed to do so. 

The Chairman. Senator Golden, we very much acknowledge the 
very important contributions you have made in terms of raising so 



160 

many of these issues. I'm grateful for your presence here this 
evening. 

Let me ask you, given what you have said about the evacuation 
plans, do you think it is possible to develop an effective evacuation 
plan at this point? 

Mr. Golden. I believe it would be very difficult. Senator, to de- 
velop an effective evacuation plan. I believe, given the limited 
transportation routes in this area, we've lost effectively 180 degrees 
because the plant is on the shoreline, and because of the limited 
north, south, east and west transportation access that we have to 
the site, I believe that if the plant was to restart, it would require 
significant sheltering plans with shelters that were properly 
equipped and those that could withstand the pressure and stress of 
the public's access to them. Right now, we don't have that. There 
are people who are being sheltered in 2-foot crawl spaces, according 
to the existing plan, and in buildings that don't exist any more. So 
we need a lot of input 

If I could just briefly respond. Senator, to your question about 
access to the public. I would like to see Congress change the 
Atomic Energy Act and permit the Governor of a State, as a 
matter of right, to demand a show cause petition. Our Governor 
has requested a show cause hearing. I believe each Governor of 
each State should have that right, at legist, and that would open 
the public process. The public process could also be opened up, I 
believe, by enabling local government, as well as State government, 
a role in the formulation and implementation of these plans, and 
with that role, the veto power over the plants for their own com- 
munities because they do know their communities well. 

The Chairman. Let me ask just quickly and then we can move 
on. You stressed in your statements you've made on this issue in 
other forums, the importance of development of cheap energy. Are 
your views tonight consistent with what you would like to see in 
terms of development of cheaper energy? 

Mr. Golden. Yes, Mr. Chairman. One form of cheap energy pro- 
duction is energy conservation. As Rachel Shimshak from 
MASSPIRG has indicated, this company, through its own commit- 
tee, the Hogan committee, it was chaired and directed by the 
United States — former U.S. Senator Saunders, indicated this com- 
pany by the year 2000 saved a thousand megawatts of power. The 
company in response would request a proposal, a proposal submit- 
ted in excess of 2,000 megawatts. 

All of that power would provide, I believe, a cheap alternative to 
Pilgrim. Given the fact especially, Mr. Chairman, that since April 
of 1986, when this plant was shut down, there has been expendi- 
tures totaling over $300 million for replacement power and con- 
struction cost on this plant. That's $300 million, and we're not any 
better off today with all that expenditure than we were 20 months 
ago when the plant was shut down. 

The Chairman. Just quickly, Mr. Alexander. 

Mr. Alexander. Thank you. Senator. Certainly the cheapest 
form of power is conservation — where we don't have to produce 
more power. An example of conservation's potential is the Appli- 
ance Efficiency Law that was passed here in Massachusetts. This 
one law alone — by only allowing stores to sell energy-efficient re- 



161 

frigerators — will each year by the year 2000 save us an amount of 
power equivalent to approximately half of the output of the Pil- 
grim nuclear power plant. One simple law will do that. The Feder- 
al appliance efficiency law is going to save the equivalent amount 
of energy as about 23 nuclear powerplants. 

It also needs to be said that if you do need new sources of power, 
it makes much more sense to have in place small generating facili- 
ties that are relatively local, so that if one, for instance, has an 
outage, we don't all of a sudden face the kind of crisis that the 
New England power pool suggests we're going to have, when a 
couple of nuclear powerplants are down for total plant mainte- 
nance. 

Mr. FoRMAN. I have a slightly different view on the importance 
of conservation. Any sound energy policy obviously has to include 
conservation, but I think that we are somewhat misguided in as- 
suming that in a region that is growing, an economy that is grow- 
ing £ind dependent on energy, that we're going to survive for too 
long in the future simply by conserving. There is a finite limit on 
how much we can conserve £ind continue to grow. 

Mr. Alexander. I think one of the great problems we have in 
this country is that we don't have a national energy policy that 
anyone can identify, and from what I can tell, the State doesn't 
either. I don't know of any states that do have a policy, and that's 
a real problem. It doesn't have to be based on nuclear. Clearly, we 
can have energy policy without it, but both the State and the coun- 
try, we need some sound energy policy that will go way beyond 
conservation and talks about generation of new power sources for 
growing areas, such as a fossil plant in Weymouth. [Applause.] 

The Chairman. Thank you very much. I want to first of all 
thank you, and the people of Plymouth, through you, for all of 
their willingness and hospitality this evening and for helping us so 
much with this hearing. 

I have just one point. As I understand your testimony, the Plym- 
outh Board of Selectmen has made their objections known to the 
NRC concerning restarting of the plant without an adequate pre- 
paredness plan. I would like to ask you how the NRC has respond- 
ed to your concern. 

Mr. Malaguti. We have constant communication with the NRC. 
We had indications that they are receptive to our comments. 

The Chairman. Did they say they wouldn't restart until they 
worked out the new evacuation plan? 

Mr. Malaguti. No, sir. They have not. 

The Chairman. Do you think they should? 

Mr. Malaguti. Absolutely. 

The Chairman. OK. Ms. Shimshak, we'll include all of the 
MASSPIRG studies in the record. The first is the 1983 report enti- 
tled "Blueprint for Chaos," and then there is the 1987 report enti- 
tled "No Exit," and finally there is the other 1987 report entitled 
"Nuclear Lemon." All those will be included. 

[The documents referred to above follow:] 



162 









■-*:^Ti^. ,;',', 









^^m^-i 






Boston, m OZU^ 
617,423-1795 ' 




THE MASSACHUSETTS PUDLIC IfUEREST RESEARCH GROUP 



163 



Acknowledgments 

Glenn Lamb and Carrie Wehllng, MASSPIRG summer interns, provided 

» 

subBtantial assistance with data collection and telephone surveys of 
special institutions in the Emergency Planning Zone. Telephone surveys 
of residents were conducted by Eric Dohlman, Jennifer Krouse, Paula Lenzl, 
Carrie Wehllng, Arthur Rounds, Claudia Basso, Wyatfe Moor, Wayne Stec, 
Leslie Stebbins, and Robert Scudder. Thanks also to Nonna Giunta for her 
administrative assistance and to Matthew Mattingly for Illustrations. 

Special thanks are also due Jack Dolan and Frank Willard of the 
Mass. Civil Defense Agency who have given generously of their valuable 
time to discuss the emergency plans at length. 

Consultation was also provided by "Doc" Mark Boehnert, M.D., 
Steven Sholly of the Union of Concerned Scientists, Kathleen Welch of 
NYPIRG, and Richard Udell of the Oversight & Investigations Subcommittee 
of the Committee on Interior and Insular Affairs of the U.S. House of 
Representatives. 

Thank you all for your contributions to improving emergency 

preparedness at Pilgrim. 

Michael Ernst 
July 20, 1983 



164 



TABLE OF CONTENTS 

Page 

EXECUTIVE SUMMARY 

EMERGENCY PLANNING: AN OVERVIEW 1 

The Need for Emergency Planning 1 

Emergency Planning in Massachusetts 3 

I. * THE EMERGENCY PLANNING ZONE 7 

II. ADVANCE INTORMATION TO THE PUBLIC 10 

III. NOTIFICATION DURING AN ACCIDENT 16 

Notifying Authorities 16 

Notifying the Public: Sirens 17 

Notifying the Public: Emergency Broadcast System ... 19 

Notifying the Deaf 20 

IV. EVACUATION PLANS. SHELTERING, AND OTHER PREPARATIONS ... 22 

The Decision to Evacuate 22 

Special Population Groups . 27 

Cape Cod 32 

Reception Facilities 33 

Medical Facilities 35 

Sheltering 36 

Emergency Drills 39 

CONCLUSION ^1 

FOOTNOTES ^3 

APPENDICES 

A. Telephone Survey of Residents 

B. Survey of Major Campgrounds 

C. Survey of Local Civil Defense Directors 

D. Survey of Correctional Facilities 

E. Survey of Ambulance Services 

F. Survey of Nursing Homes 

G. Survey of Hospitals 



165 



EXECUTIVE SUMMARY 



As a result of the partial core meltdown at Three Mile Island, the \ 
Nuclear Regulatory Commission (NRC) was forced to concede that dangerous 
quantities of radioactivity could escape from nuclear power reactors and 
that workable evacuation plans were necessary to protect the public. A 
government study estimated that a very serious meltdown at Pllgtla Nuclear 
Power Station in Plymouth, MA, could kill 3,000 people. Injure 30,000 
more, and cause 23,000 fatal cancers. 

Effective emergency planning and preparedness can greatly reduce 
radiation exposure because some reactor meltdowns would take many hours 
to develop and provide ample time for evacuation. For faster developing 
meltdowns, proper sheltering with breathing filters and a drug to protect 
the thyroid glands would reduce the health consequences. 

Unfortunately, more than two years after the NRC deadline, the 
Pilgrim emergency response plans remain woefully inadequate in violation 
of state and federal law. The Federal Emergency Management Agency (FEMA) 
has Identified 73 deficiencies in the plans and emergency drills. MASSPIRG's 
research reveals additional problems so serious as to place the population 
in and near Plymouth and Cape Cod at extreme risk if a meltdown occurred. 



166 



- 2 



Hlghllghta of MASSFIRC findings ; 

* Evacuation planning only applies to a lO-mlle radius around Plymouth, excluding 
Cape Cod, even though government studies estimate a serious meltdown could kill 
3,000 people up to 20 miles from the reactor. 

* Only two-thirds of the permanent residents and no tourists have received 
energency information, which is lncoiq>lete, inaccurate and contradicts the 
official plans anyway. 

* There are insufficient warning sirens that are not loud enough, and fully 
three-<iuarters of the area residents have heard false alarms. 

* There are no workable plans for evacuating the physically disabled, nursing 
home residents, school children, hospital patients, campers, inmates or people 
without cars. 

* Cape Cod will receive no early warning of a meltdown and the Cape bridges Will 
be closed to prevent Cape traffic from interfering with evacuees from closer 
to the reactor. 

* Sheltering, medical and evacuation reception facilities are grossly inadequate 
to care for the 120,000 summer residents and tourists (not counting the 
summer Cape population of 1/2 million) . 

MASSPIRG calls on the NRC to consider shutting down or reducing the operating 
power of Pilgrim until emergency preparedness is substantially upgraded. MASSPIRG 
also recommends that the Governor establish a public emergency planning commlssioa 
with local representation to oversee the development of workable emergency plans. 



167 



EMERGENCY PLANNING: AN OVERVIEW 

"Every man for himself!" According to the director of the Indian 
Head Campground, south of Plynouth, Massachusetts, that Is the extent 
of the evacuation plan for as many as 1,000 campers there In case of a 
meltdown at the Pilgrim Nuclear Power Plant just seven miles north. 

Unfortunately, that seems an apt characterization of the evacuation plans 
for all the physically disabled, elderly, nursing home residents, tourists, 
hospital patients, and those dependent on public transportation who are 
in the vicinity of Pilgrim Station. Even the Federal Emergency Management 
Agency (FEMA) acknowledges there are no fewer than 73 deficiencies in the 

emergency plana designed to protect the public in the event of a Pilgrim 

2 
meltdown. Taking into account Pilgrim's safety record, the need becomes 

urgent to develop and implement a practical evacuation plan. This study 
is Intended as an evaluation of current emergency preparedness with recom- 
mendations for realistic ways to improve the current situation. 

The Need for Emergency Planning 

Under certain reactor accident scenarios, effective emergency response 
plans could save thousands of lives. Effective public evacuation or 
sheltering can reduce radiation exposure substantially. For slow-developing 
reactor core meltdowns, radiation would not escape into the atmosphere for 
24 hours or more, providing ample time to evacuate downwind areas. Even 
for meltdowns that develop more quickly, it is essential to alert people 



168 



- 2 



Immediately so they can take shelter before the radioactive cloud 
reaches them. Like the President's Commission on Three Mile Island, 
the Nuclear Regulatory Commission's own Special Inquiry Group, com- 
* missioned to investigate that accident, concluded that "workable evac- 
uation plans" should be a "prerequisite to continued operation of 
existing and future reactors." Major Improvements in these plans were 
recommended by both investigations. 

En^rgency preparedness is crucial because even though the likeli- 
hood of a meltdown is not great, the consequences of a serious radiation 
release are horrendous: the government now estimates that a "worst-case 
accident" at Pilgrim could kill 3,000 people within a year, injure 30,000 

Q 

more, and cause 23,000 fatal cancers. Total damages could exceed 
$80 billion, not including medical expenses. Even a minute chance of 
such an accident is cause for concern In light of its potential severity. 
The NRC discovered that the Three Mile Island reactor was "within 30 to 60 

minutes" of a major core meltdown with "potentially serious public health 

9 
and safety consequences." A Nuclear Regulatory Commission (NRC) report 

released last summer evaluated almost 20,000 "mishaps" at nuclear power 

reactors from 1969 to 1979 and concluded that accidents as serious as that 

at Three Mile Island were likely to occur once every three to eight years 

somewhere In the country. Directly after the Three Mile Island accident, 

in fact, the President's Commission convened to study the matter and made 

about 100 recommendations. Its report concluded that even the adoption 

of these "necessary fundamental changes" could not assure the safety of 



169 



- 3 



nuclear power. In fact, only a handful of these "necessary" changes 
were ever adopted by the NRC. 

If nuclear power In general Is cause for concern, the safety record 
of the Pilgrim plant In particular Is positively alarming. Of the 54 

most serious "meltdown precursors" at nuclear plants nationwide during 

12 
the last decade, four occurred at Pilgrim. The Plymouth plant averaged 

one mishap a week during 1981 and was rated "below average" by the NK.C 

In overall management and in reactor safety performance. Boston Edison, 

which owns and runs the facility, was fined $550,000 in early 1982 — the 

largest fine ever collected from an American nuclear power plant operator • 

for disconnecting a major safety system for 2^ years and then making a 

"material false statement" about it. 



Emergency Planning in Massachusetts 

The Nuclear Regulatory Connisslon's Special Inquiry Group on Three 
KLle Island discovered that the NRC, because of a "prevailing attitude 
that a serious accident with releases beyond containment simply would 
not happen," iiad not taken seriously its authority over emergency plan- 
ning. Both the Special Inquiry Group and the President's Coimlsslon on 
Three Mile Island recommended preparedness around nuclear plants should 
be transferred from the NRC to the Federal Emergency Hanageiaent Agency 
(7EMA). While retaining final authority over the emergency plans, NRC 



170 



- 4 - 



did Issue new regulations in 1980 Chat require FEMA to review and 

comment on all state and local plans. Workable plans were supposed 

18 
to be in place by April 1, 1981. The regulations require FEMA and 

the NRC to determine whether plans "adequately protect the public health 

and safety by providing reasonable assurance that appropriate protective 

19 

measures can and will be taken in the event of a radiological emergency." 

Tet even if NRC ultimately determines that a given set of plans 
are inadequate, the reactor would be permitted to continue operating 
provided the utility could show that any deficiencies were "not signif- 
icant," that "compensating actions have been or will be taken promptly," 

20 
or that "other compelling reasons" exist to permit plant operation. 

Indeed, the NRC has already used this escape clause to permit the con- 
tinued operation of the Indian Point reactors in New York. Despite FQ(A 
findings that the emergency plans for Indian Point still contained sig- 
nificant deficiencies more than two years beyond the deadline, the NRC 

21 
refused to take any enforcement action. NRC Commissioner Asselstine 

charged the decision "made a mockery" of the NRC's regulations. 



The burden of drawing up emergency plans in the Commonwealth falls 
to the Massachusetts Civil Defense Agency. In the event of a serious 
accident at Pilgrim, Boston Edison's reactor operators are to notify 
state police while taking steps to prevent a radioactive release. The 
state police in turn notify the Department of Public Health (DPH) , 



171 



5 - 



state and local civil defense officials and local town selectmen. DPH 
has primary responsibility for determining the extent of danger presented 
to the public and recommending protective actions. Radiation information 
•Is obtained directly from the utility and from independent evaluation 
teams in the field. These "Nuclear Incident Advisory Teams" from Boston 
collect air samples downwind from the reactor and perform radiation 
analyses. On the basis of this information, the DPH recommends a course 
of action to the Governor. Evacuation may be ordered by the Governor, the 
Commissioner of Public Health, the state director of civil defense, or by 
the local Board of Selectmen. The Civil Defense Agency actually conducts 
the evacuation. (The plan, of course, contains further specifications 
regarding the notification of the public and evacuation procedures, and 
it is these details with which the present report is particularly concerned.) 

The attempt by Boston Edison and state civil defense to develop a 
comprehensive emergency response plan, however, was doomed from the start 
by the failure to Include local communities in the planning process. 
Only long-term residents have a complete understanding of local resources, 
capabilities, needs and even likely evacuation obstacles. As a result, 
carefully planned "emergency" drills may demonstrate the ability of emer- 
gency officials to communicate with each other, but they do not indicate 
whether 100,000 local people could be notified, mobilized and evacuated 
in case of a real emergency. 



172 



- 6 



In 1977, MASSPIRG published a report evaluating emergency plans 
for nuclear reactors In Massachusetts. The report, entitled "Nuclear 
Evacuation Planning: Blueprint for Chaos," concluded that planning was 
"shoddy and a reactor accident would place citizens' safety in Jeopardy," 
Six years later, we are forced to reach the same conclusion, 

A careful review of the current emergency plans reveals major prob- 
lems with every section. In Septenfcer of 1982, FEMA found 73 deficiencies.^ 
Not only do the plans fall short of FEMA's basic standards, but they seem 
sloppily concleved and Incapable of implementation. The result, we fear 
could be tragedy on a mass scale. The plan is analyzed in four chapters, 
as follows: first. The Emergency Planning Zone size is evaluated to 
determine whether the plan is designed to protect all the residents who 
actually would be affected by an accident; second, we examine the procedure 
for informing residents in advance about what to do in case of an accident 
at Pilgrim; third, the emergency warning system, intended to inform residents 
at the time of an accident, is evaluated; and finally, we examine the actual, 
evacuation and sheltering plans and other procedures for protecting the 
populace. Specific recommendations for improving the emergency plan are 
offered after each section. 



173 



I, THE EMERGENCY PLANNING ZONE 

The first consideration in regard to planning for a nuclear power 
plant accident is the size of the area involved. This is known as the 
Emergency Planning Zone (EPZ) , and it obviously should be large enough to 
Include virtually all people who would likely be exposed to significant 
doses of radiation in case of a reactor malfunction. In fact, though, current 
plans limit the EPZ to areas within 10 miles of Pilgrim. This is a conse- 
quence of both NRC guidelines and a determination by Boston Edison and the • 
Civil Defease Agency. In any case. It proves on inspection to be absurdly 
Inadequate, with the result that thousands of people who might suffer from a 
nuclear accident are utterly without protection in the emergency plans. , 

The NRC has decided Chat EFZ's should be about 10 miles in radius, 
with site-specific adjustments based on local "demography, topography, 
land characteristics, access routes, and jurisdictional boundaries," 
The effect of these additional criteria is considered below, but it should 
first be noted that even as a rough guideline, a 10-mile EPZ is wholly In- 
adequate. Several lines of analysis lead to this conclusion: 

* The NRC's own rationale is that 70Z of core meltdowns would not 

2 
result in harmful doses of radiation beyond 10 miles for a typical reactor. 

By Its own estimate, then, the suggested EPZ would be inadequate for nearly 

a third of all major accidents. Of this group, two-chirds will result 

in harmful doses out to 20 miles, and the remainder to between 40 and 50 

miles. 



174 



- 8 - 



* A recent govemnent study determined that a worst-case accident 
at Pilgrim could kill people as far as 20 miles from the reactor and cause 
Injuries 65 miles away. (Boston city limits are less than 35 miles from 
the plant.) 

* If adequate EPZ size Is best judged under actual accident 
conditions, it is useful to recall that the NRC ordered evacuation plans 
developed for those living within 20 miles of Three Mile Island. 

* California took seriously the hazards presented by major melt- 
downs and established EPZ boundaries ranging from 18 - 35 miles from the 

^ 6 
reactor . 

The NRC 10-mile EPZ is based on an outdated accident probability study, 
and Is proposed with the suggestion that more serious accidents could be 

Q 

handled on an "ad- hoc basis." (Thus, the varied and complicated infor- 
mation needed to effect an evacuation, much of which is not even available 
for the 10-mile EPZ after three years of planning, is supposed to be 
collected in a matter of hours.) Yet even the woeful inadequacy of these 
guidelines is somewhat mitigated by the criteria offered for site-specific 
adjustments, listed above. Unhappily, all of these criteria but one have 

been Ignored in designating a 10-mile EPZ for Pilgrim. Only the jurisdic- 

9 
tional boundaries of area towns were considered; the high population 

density of the area, particularly during the summer, was not a factor. 

Neither were topography, land characteristics, or access routes. People 

outside the designated EPZ are very likely to evacuate even if not required 

to do so: 2,500 women and young children were ordered to leave the Three 



175 



- 9 



Mile Island area, but 144,000 actually left. Planning must account 
for this de facto evacuation and the question of access routes becomes 
particularly critical. The only expressway in the area. Route 3, is 
already jannned on summer weekends, and the only exits off Cape Cod are 
two bridges less than 15 miles from the reactor. Incredibly, the Civil 
Defense Agency has decided that if the wind is blowing south when a 
serious accident occurs, the Cape bridges are to be closed. If resi- 
dents Just outside the 10-mile EPZ are not included in emergency planning, 
they will not receive information on where and how to evacuate or whether 
to take shelter instead of evacuating. Limiting the size of the EPZ 
without consideration to the certain evacuation of those outside it 
therefore results in creating greater danger for residents both inside 
and outside of the zone. 

Recommendations : 



A site-specific analysis of accident probabilities and consequences of 
radioactive releases and of the probable health effects at various 
distances from the plant should be undertaken promptly. Civil 
Defense -should hire independent consultants for this purpose, with 
Boston Edison paying all attendant costs. The ultimate objective should 
be to establish an emergency planning zone including Cape Cod that covere 
all persons at risk of receiving harmful doses of radiation from major 
core meltdowns. ^ 



176 



- 10 



II. ADVANCE INTORMATION TO THE PUBLIC 

No plan for a nuclear accident can hope to save lives If residents 
know nothing of its provisions until the accident occurs. Conmon sense 
dictates that the public must be familiar with evacuation and sheltering 
procedures before a major crisis develops, as well as the relative 
benefits of these two responses. There is evidence that many people will 
evacuate before directed to do so, and many others will not evacuate even 
when ordered to leave. 

Recognizing the importance of advance public information for emer- 
gency preparedness, FEMA and NRC developed several criteria to promote 
maxlnua public education on protective actions. Specifically, the federal 
ccl^terla require provision of information on nuclear radiation hatarda, 
protective measures Including evacuation routes, sheltering, respiratory 

protection, radioprotective drugs, special needs of tourists and the physically 

2 
disabled, and where to get additional Information. 

Adequate dissemination of information involves using several methods 
rather than just one. FEMA and NRC recommend including emergency infor- 
mation In the phone book and with utility bills, as well as posting notices 
In public areas. New York's public education program includes public ser- 
vice announcements on the radio, newspaper advertisements, and a speakers' 
program, while the EPZ for Verncnt's Yankee nuclear plant contains large 
orange posters. In the Plymouth area, by contrast, a pair of emergency 
pamphlets is the only method for informing the public about a nuclear 



177 



11 - 



emergency. Beyond the general Inadequacy of this situation, some 

451000 tourists who are in the area each summer weekend and 24,000 

4 
seasonal residents are utterly without Information. FEMA considers this 

glaring omission a "significant deficiency." The Chamber of Commerce 

has opposed any efforts to educate the tourists for fear of scaring 

them away. 

Even if the two pamphlets, prepared by the DPH and Civil Defense 

Agency, were universally distributed and exemplary, they would be 

insufficient to educate the public. In fact, though, they are neither. 

The two publications — "Emergency Public Information," with evacuation 

and sheltering instructions, and "Nuclear Energy — Questions and 

Answers," with more general Information on radiation — were supposedly 

mailed to all households in the EPA in the fall of 1982. MASSPIRG's 

telephone survey of 100 area residents, however, discovered that only 

2/3 of the respondents had ever received the pamphlets and Just 1/6 

still had them available. Emergency authorities have made no effort 

to ascertain how many pamphlets were received or how little their contents 

were understood. Only 9X of the respondents knew they should tune in 

their radio or TV to an Emergency Broadcast system station when they 

g 
heard the Pilgrim warning siren. 

As regards the contents of the brochures, serious deficiencies 

exist: 

(1) The educational information on radiation in the "Nuclear 

Energy" pamphlet does not convey the real danger of serious meltdowns. 



178 




179 



- 12 



The probability estlnaces of melcdowns from the outdated 1975 Reactor 

9 
Safety Study are called the "best available." The pamphlet also 

understates the hazards of radiation releases from reactors. The effect 

is to reinforce the inclination of many people to ignore evacuation 

orders. Less than 1/3 of the survey respondents realized that radiation 

released from a major meltdown could cause death. If ordered to evacuate, 

7Z (nearly 4,000 people) would not leave. 



(2) The Plymouth Town Plan stipulates that "most residents of 
nursing homes will be evacuated by private automobile." but the 

"Emergency" Pamphlet specifically warns that people should not pick up 

12 
nursing home residents because transportation will be provided for them. 

(3) While the Plymouth Town Plan Includes 13 "staging areas" 

where "persons without transportation will be directed for possible public 

13 
transport," the Emergency Pamphlet makes no mention of their existence 

or locations. 

(4) Sheltering instructions (found only in the Nuclear Energy 
Pamphlet) provide no directions to public shelters for tourists or 
residents without basements. There are no Instructions on ad hoc 
respiratory protection from contaminated air. 

(5) Regarding evacuation of the physically disabled, the pamphlet 
siiqtly states: "The disabled and those requiring special assistance 



180 



13 - 



^hould concact the (local civil defense) offices listed belov so that 
adequate preparation can be made and assistance provided. Do not call 
during an emergency unless absolutely necessary . " There is no elabor- 
ation on evacuation procedures for the disabled. The MASSPIRG survey 

revealed that n£ one had called the Plymouth Civil Defense to arrange 

14 
for evacuation assistance yet. That means when an accident happens, 

everyone needing transportation assistance will be trying to call the 

civil defense office at the same time everyone else in town is trying 

to call there to find out what's going on. With everyone calling the 

office, very few will get through (phone lines to the police are already 

tied up whenever the sirens go off accidentally ). 



(6) Four of the five telephone numbers listed for "local civil 
defense offices" do not reach these offices and none reach the local 
civil defense director. The phone nunijer listed for Carver Civil 
Defense is the number for reporting burglaries at the police station, and 
the first forwarding number provided for the civil defense director turned 

out to be a wrong number! The failure to update phone numbers in the 

18 
plan quarterly was considered a "significant deficiency" by FEMA. 



(7) The state plan directs that "the special needs of persons 

19 
within the EPZ who are ... non-English speaking" will be addressed. 



181 



This is especially important in North Plymouth and other neighborhoods 
In the areas vhich contain large Italian and Portugese communities. The 
Emergency pamphlet, however. Is published only in English. 



Recommendations : 



1) The Nuclear Energy Pamphlet should be updated with the latest federal 
estimates of the probability and consequences of serious laeltdowns to 
Impress upon the public the importance of following official instructiona 
during an emerge.icy. 

2) The State and Town Plans and the Emergency Pamphlet must be updated to 
provide realistic and consistent emergency response plans. 

3) The location of "staging areas" for public transportation must be 
included on maps in all emergency information materials. 

4) The location of public shelters must be Included on maps in all 
emergency information materials. 

5) A confidential list of all physically disabled persons in the EPZ 
should be compiled by civil defense officials, and practical plana for 
their evacuation should be developed. Practical plans for evacuating 

the physically disabled, school children, nursing home residents, hospital 
patients, canqjers, institutionalized persons and people without 24-hour 
access to cars should all be clearly spelled out in all emargency information 
materials. 

6) The correct telephone numbers for the local civil defense offices or 
directors should be Included in all emergency information materials. 

7) A comprehensive public education program including radio and TV 

public service announcements and a speakerNLs bureau to educate all residents 
of the EPZ should be implemented to supplement the pamphlet. This program 
should include an evaluation component to confirm that the public is 
being adequately informed, 

8) A program must be developed for providing emergency information 

to tourists through distribution of Emergency Pamphlets, large posters, 
and telephone book inserts to all "hotels, motels, gasoline stations," 
restaurants and other public facilities in the EPZ. 

9) Emergency information materials should be distributed in Portuguese, 
Italian and Japanese. 



182 



16 



HI. NOTIFICATION DURING AN ACCIDENT 

Assuming all the people In the EPZ were pro\d.ded with sufficient 
Information so that they were prepared to react properly in an emergency, 
it would still be necessary to provide immediate and comprehensive no- 
tification as soon as trouble was detected. Federal authorities estimate 
that a nuclear accident could release substantial amounts of radioactivity 
as early as 30 minutes after the "initiating" event. Once again, 
people living in the vicinity of the Pilgrim plant are endangered due 
to Inadequate planning. 

Notifying Authorities 

Under current plans, the scheduled chain of emergency responses is 
begun by Boston Edison's reactor operators. The very organization with 
the greatest investment in convincing people that nuclear power is safe, 
in other words, has the discretion to decide when (or whether) to tell 
the state police that something has gone wrong. An incentive exists for 
Edison's reactor operators to delay reporting until they can correct the 
malfunction and then report that everything is under control. Indeed, 
within the past year alone, the NRC discovered three notification viola- 
tions for Boston Edison's failure to provide prompt notification of 
problems which developed during reactor deration. While two NRC 



183 



- 17 - 



Inspectors are assigned to oversee operations at Pilgrim, they are 
on duty for only about half of the operating hours. 

, Notifying the Public: Sirens 

The NRC now requires a system capable of notifying the public In the 

3 
EPZ vrlthin 15 minutes — a requirement curiously Interpreted by FEMA 

to refer only to people living within five miles of the site, with those 
In the rest of the EPZ to be notified within 45 minutes. In fact, the 
current siren warning system in and around Plymouth meets neither of 
these specifications. This is demonstrated, first, by admissions from 
the system's designers, and second, by results from a siren test. 

Stone & Webster Engineering Corporation designed the fixed siren 
alert system to reach about 902 of EPZ residents and 98% of those living 
within five miles. The conqjany recommended installation of 250 tone- 
activated Emergency Broadcast System (EBS) alarms to make sure the remain- 
ing people within five miles were notified and to provide back-up notifi- 
cation for "schools, hospitals, nursing homes, police and fire departments, 
and possibly for some hotel/motel offices." Even if these EBS receivers 
were provided — and they have not been — the engineering firm admits that 
some people living between five and ten miles from the reactor would not 
hear a siren. In effect, the very design of the siren system now in use 
fails to meet federal requirements. 



184 



- 18 - 



On June 19, 1982, the whole siren system was tested. Almost half 
(473!) of the FIMA observers reported the sirens were "inaudible" or "barely 
audible." The sirens "did not generally wake people that were asleep," 
and between seven and nine of the 90 sirens did not work at all. Noting, 
moreover, that the test was conducted on a warm summer day, the observers 
determined there was a "strong possibility that a significant portion of 
households within the EPZ would not be alerted by the fixed siren signal 

Q 

under adverse conditions" with windows and doors closed. Their suspicions 

were confirmed by nearly half of the MASSFIRG survey respondents for both 

9 
offices and homes. FEMA concluded that "fixed sirens alone will not Insure 

the necessary coverage." After a similar evaluation at Indian Point, 

the utilities there agreed to Install an additional 17 sirens. 

In addition, the observers reported several unsolicited complaints 

12 
from residents that the sirens were often activating accidentally. The 

MASSFIRG survey found that 77Z of respondents had heard unplanned sirens. 

Two-thirds of these people had heard at least three and ISZ heard more than 

7 false alarms! FEMA stated that accidental activation of sirens reduces 

their credibility, "causing some residents to disregard the alerting signal." 

This assertion was also corroborated by the MASSFIRG survey: 19Z of 



respondents said if they heard the siren again, they would assume It was 
accidentally activated and Ignore it. We also were asked the following 
question: "Why can't they Improve the sirens so people would believe them7" 



185 



"Why can't they Improve the sirens so people would believe them?" ^^ 

To determine whether a siren was a false alarm, nearly one-third 
of those surveyed said they would telephone someone — usually the 
poll,ce or fire department. The fact that no one will be able to get 
a call through has already been demonstrated. The superintendent of 
the state prison in Plymouth con^ilained that even he could never find 
out what was going on. "The sirens are always going off. The inmates 
and staff panic and I don't know what to do - so I call the police but 
1 can never get through." 

Finally, back-up vehicles with loudspeakers are supposed to go 
out and alert all areas where the sirens don't work. Unfortunately, there 
is no plan for discovering which sirens don't work. 

Overall. FEMA concluded the siren system did not meet "minimum 
federal standards." ^^ 



Notifying the Public; EBS 

Federal guidelines also call for civil defense officials to notify 
Emergency Broadcast System (EBS) stations in the evBnt of a serious 
accident. '5 Anyone watching television or listening to the radio would 
be instructed to turn to an EBS station which, in turn, would provide 
emergency instructions. On June 3, 1982. an accident occurred that was 
claasified as serious enough to warrant notification of EBS stations, but 
this did not happen. 



186 



20 



Rumors about the severity of the accident spread as a result, and many 

20 
citizens were understandably upset. Even during the official 

emergency drill last year, officials failed to notify one of the EBS 

21 
stations. 



Notifying the Deaf 

According to the Massachusetts Office of the Deaf, 39,000 people 
in the CommDnwealth are totally deaf and another 335,000 have serious 
hearing deficiencies. Of the 80,000 residents in the Pilgrim EPZ, 
there are probably at least one hundred deaf people and another thousand 

who would be unable to hear the warning sirens, let alone radio announce- 

22 
ments or telephone warnings. 

Federal regulations require notification of "all segments" of the 

23 
population, and the state plan directs that "TV overprinting will be 

provided for hearing-impaired persons on area EBS television broadcasts 

during an emergency." But what of those people in the target group 

who do not happen to be watching television when an accident occurs? 

Local officials are to maintain "confidential listings of households and 

25 
individuals requiring assistance due to special needs.' No such lists 

have been compiled, and no plan exists to notify the hearing-impaired 

promptly in case of emergency. 



187 



- 21 



Reconmendaclons : 



1) TniC Inspectors should be on duty In the reactor control room 

24 hours a day to insure the Imniediate notification of emergency officials 
whenever problems develop. 

2) Enough sirens should be Installed so that tests confirm lOOZ coverage 
of Che EPZ with windows closed. 

3) Alarms should be installed in every non-residential building in the 
EPZ, with a procedure developed to confirm that the sirens are in 
working order. 

4) A system for determining promptly whether every siren is functioning 
oust be iiq)leaented. 

5) Civil defense officials should determine the number of vehicles with 
loudspeakers necessary to alert residents of any area within 45 minutes in 
case a siren fails. 

6) Boston Wison should provide a teletypewriter for every deaf person 
in the EPZ.^° 

7) Capability for TV overprinting for hearing impaired tourists and 
seasonal residents must be available on a 24-hour basis. 



188 



22 - 



IV. FVACUATION PLANS, SHELTERING, AND OTHER PREPARATIONS 
The Decision to Evacuate 

In the event of an appreciable release of radiation, officials must 
decide promptly whether to order evacuation or sheltering of the public 
downwind from the reactor. Evacuation Is the preferred protective action 
because it prevents any radioactive exposure. Since cars provide very 
little shielding against radiation, however, sheltering in basements or 
large buildings provides greater protection from radiation exposure if 
there were insufficient time to evacuate before the radioactive cloud 
passed through the area. 

If an order to evacuate is given with insufficient time to clear the 
area, thousands of people could be trapped in bumper-to-bumper traffic 
and irradiated as they are overtaken by the radioactive cloud. Before 
ordering an evacuation, emergency officials must be reasonably confident 
that the time necessary to evacuate an area is shorter than the time it 
will take for the radiation to escape from the reactor and blow through 
chat same area. 

The decision to order evacuation or sheltering, therefore, depends 
on three key estimates: the timing of a release of radioactivity from the 
reactor, the direction and velocity of the radioactive cloud after release, 
and the amount of time required to evacuate the area. Unfortunately, 
the weather bureau's prediction of wind velocity and direction 



189 



23 



over the next several hours is likely to be more reliable than the 

other tvro estimates. Emergency officials must rely on Boston Edison's 

reactor operators to give an accurate estimate of the time of release. 

Hajor accidents can result in releases of radioactivity into the air as 

early as half an hour or as late as a day or more after the accident 

2 
begins. Depending on the particular accident scenario, guessing when 

a significant release of radiation may occur could be a very speculative 

task. 

The estimates of the amount of time necessary to evacuate downwind 
areas, while also speculative, are the only estimates that can be. pre- 
dicted even roughly in advance of an accident. Boston Edison hired 
transportation consultants, HMM Associates, to develop evacuation tine 
estimates through the use of a sophisticated computer code. Their results, 
however, are based on completely unrealistic assumptions and seriously 
underestimate the time that would actually be required to evacuate each 
sector. 

More specifically, they ignored the fact that obstacles to heavy 
traffic flow outside the evacuation zones will Impair prompt evacuation 
Inside the areas ordered to evacuate, that many people outside designated 
evacuation zones will also evacuate, that some drivers will panic and 
create traffic disorder, that thousands of residents do not have 24-hour access 
to a car and will need public transportation, and that different types of 
adverse weather and evacuating at different times of the day and the week 
will also affect the time necessary to evacuate various areas. 



190 



24 - 



HMM Associates estimated It would take 160 minutes to evacuate the 

10-mile sector south of Pilgrim Station. NRC consultants conducted a 

3 
separate analysis and produced an estimate of 410 minutes. HMM Associates 

then updated its study to include a "critical bottleneck" in traffic at 

the Sagamore rotary, Just one mile outside the EPZ, and concluded the 

4 
correct time was 315 minutes. A discrepancy of over an hour and a half 

still remains. One wonders how many other traffic factors — jams on 
Routes 6 and 25, for example — were not considered in one or both 
analyses. 

HMM Associates also stubbornly refuses to acknowledge that people 
living outside the designated evacuation sectors are likely to leave. As 
noted earlier, 144,000 people evacuated from around Three Mile Island even 
though only 2,500 people were ordered to do so. This single piece of 
evidence is so compelling as to demand that evacuation estimates be re- 
considered immediately. As one study put it: 

In planning for an evacuation from a nuclear 
disaster, it can therefore be projected that 
any order to evacuate will cause the departure 
of residents not only from a designated zone 
but also from its peripheries. 

The attendant traffic Jams from this phenomenon would likely be so enor- 
mous that untold thousands would be in extreme danger, and this situation 
is exacerbated by the failure to educate those outside the EPZ about 
evacuation routes or procedures. 



191 




o 
•o 



0) 

E 
o 



■a 






4-1 

o 



■a 






u 

V 

u 
v 



> 

u 



41 



192 



25 



Furthermore, neither the estimates by HMM Associates nor by the 
NRC allow for the possibility of panic and traffic disorder. Substan- 
tiating this commonsense concern was a 1980 report by transportation 
consultants for FEMA: "Experiences such as major snowfalls (even in 
regions accustomed to such types of weather) suggest that driver behavior 
deteriorates quite regularly under circumstances of 30- to 90-minute 
delays." One could expect such behavior as blocking cross streets, 
disregarding traffic signals, driving in the left-hand lane against 
traffic, abandoning vehicles, and many accidents as a result, according 
to the study. In fact, it predicted a 50% reduction in traffic flow 
compared to disciplined traffic. With ineffective traffic control, 
evacuation estimates concerning the Seabrook plant should be doubled. 
Yet those people preparing estimates on the time necessary to evacuate 
the Plyncuth area — the estimates that will form the basis of a llfe- 
and-death decision — assume that normal traffic conditions will prevail. 

Moreover, the estimates by HMM Associates fail to consider the time 
necessary to evacuate the nursing homes, schools, hospitals, campgrounds, 
physically disabled and people without 24-hour access to cars. In fact, 

g 

MBTA buses will be called in from Boston. No estimates have been developed 
for the time required to bring in sufficient buses at different tines of 
the day, week, and year and under various weather conditions. Indeed, 
federal guidelines require not just one evacuation time estimate, but a 

variety of estimates for different times of the day and different weather 

9 
conditions for each sector around the reactor. Boston Edison's only 



193 



- 26 



time estimates are for peak and typical population during normal and 

10 
adverse weather, falling far short of the multiple federal requirements. 

Because of these various deficiencies — failure to account for panic, 

traffic disorder, public transportation - dependent Individuals, and 

so forth — the Mass. Attorney General also has concluded that the 

U 
evacuation time estimates are Inaccurate. 

Even if HUM Associates considers these new factors, the new time 

estimates will remain speculative. Given all the uncertainties involved, 

the decision to order evacuation should only be made when the best 

estimate for a radiation release exceeds the new evacuation time estimates 

by a substantial margin. 

Recommendations: 



1. Given the difficulty in predicting the time when radioactivity may be 
released from a meltdown, reactor operators and NRC Inspectors should be 
trained to make accurate estimates under various accident scenarios. In 
the event of an actual meltdown, reactor operators and NRC inspectors should 
give emergency officials their best estimates together with an indication 
of the level of confidence they have in these estimates. 

2. Boston Edison should pay for a new evacuation time study supervised by 
FEMA. The new study should assume that a substantial amount of spontaneous 
evacuation will occur around the periphery of designated evacuation zones, 
that traffic obstacles outside the EPZ such as the Sagamore rotary will 
affect the amount of time required to evacuate the EPZ, that some drivers 
will panic and cause traffic disorder and delays, and that a substantial 
segment of the population will require public transportation to evacuate. 
The new study must also include separate evacuation time estimates for 
various special population groups, for different adverse weather conditions 
and for various times of the day, week, and year. 



194 




195 



27- 



Speclal Population Groups 

While all residents are at risk as a result of Irresponsible and 

* 

inadequate evacuation time estimates, certain individuals are at an 
even greater disadvantage in case of emergency. The plans fall to address 
the needs of specific populations, including handicapped persons, nursing 
home residents, school children, hospital patients, and inmates as well as 
everyone dependent on public transportation. 

Civil defense authorities have made the assumption that private 

automobiles can provide virtually all of the transportation required to 

12 
evacuate the population. In fact, this is false: about 13Z of Plynouth 

13 
households, representing over 4,000 residents, do not own a car. Also, 

14 
nearly half of Plymouth's workers have jobs outside the town. Should 

an accident occur during a weekday, the plans state that these workers 

may not be permitted to return home to pick up their families. Another 

10,000 residents may therefore require transportation. 

Current plans call for sending in MBTA and other area buses to pick 

up residents without access to automobiles. There is no evidence that the 

MBTA or any private bus lines have ever been contacted about evacuation 

assistance. Beyond the fact that no written agreement exists to provide 

for this (as federal criteria require ), it would take about 350 buses to 

18 
evacuate 14,000 people — and no one has any idea how long this would 

take or whether that many buses could be made available quickly. Relying 

on large fleets of local buses raises another problem: most bus drivers 

would evacuate their own families from danger zones before reporting to drive 



196 



- 28 



an evacuation bus. Two surveys of bus drivers in New York confirm this 

conclusion, and the state of New York is connnitted to funding a "compre- 

19 
henslve study" of the mass transit evacuation problems. Finally, the 

"staging areas" where people would be picked up by buses are not listed 
in the emergency information pamphlet. 

While federal regulations require the development of plans for "pro- 
tecting those persons whose mobility may be impaired," these persons, 

20 
perhaps 1000, have not even been Identified yet. Although the Massachusetts 

Radiological Emergency Response Plan states that lists of the physically 

21 
disabled and elderly will be maintained by civil defense officials, the 

PlymDuth Plan says this: 

Because it is not feasible to maintain 
current lists of handicapped individuals 
within the towns, an inventory of local 
transportation resources, both private and 
public, that would be called upon to assist 
any individuals having special needs due to 
handicaps or disabilities will be maintained 
by the Director of Civil Defense. In addition, 
local agencies that serve the handicapped 

will be called upon to assist in the event of 

22 
an emergency. ^^ 

Even If this alternative were accepted as satisfactory. It proves utterly 

unrealistic in practice. The "local agencies" are not specified, to begin 

with. As for transportation resources, the MASSPIRG survey revealed that 

only one of the twelve ambulance and wheel chair transit companies listed 

in the plan has been contacted regarding participation in an evacuation effort. 

Only one company listed is within 20 miles of Plymouth, and it closed two 

years ago. Five of the six ambulance companies have no plans to assist 



197 



- 29 - 



and are not prepared to handle radiation victims. Gilbert Gamett, 

owner of Bristol County Ambulance, said he would not send any ambulances 

In the event of a serious accident: 

"If they want ambulances, they'll have to come get 
them. No one on my staff will go anywhere near Plymouth 
if there is an accident at the nuclear plant." 23 

Of the three wheel chair transit companies listed in the State Plan, 

one Is a duplicate listing and the second is for a company that has been 

24 
out of business for four years. FEMA's recent evaluation concluded that 

"no information is found (in the plans) that provides protection for the 

mobility impaired," calling this a "significant deficiency" in the plans. 

Only one director of all the nursing homes, campgrounds, and correctional 

facilities listed in the plans has ever been contacted about evacuation plans, 

and contradictory plans for evacuating hospitals and schools add to the 

confusion. Consider: 

* There are five nursing homes in the Plymouth area alone which 

27 
the Plymouth Plan states have a total capacity of 380 residents. The 

28 
Plymouth Plan calls for an evacuation of these residents by automobile, 

but the EPZ brochure tells people not to pick up nursing home residents 

29 
because transportation will be provided. A MASSPIRG survey found that 

the actual capacity of these homes is about 430, that none had been contacted 

about a radiological emergency (one spokesperson assuming they would have 

to "call in the National Guard"), and that it was not clear whether the staff 

was to evacuate with residents. 

* Flans call for 80 to 85 school buses to evacuate students 



26 



198 



31 - 



When pressed to explain how all these different groups of people can 
be evacuated, a civil defense official simply replied, "The Governor will 
.declare a state of emergency and we'll order buses in here." But how 
many buses are needed? From where? How long will it take for the drivers 
to report and drive them to the EPZ7 Where will they go when they get 
there? These are life and death questions that cannot wait to be answered 
correctly during the panic of a real crisis. They must be answered now so 
that all the kinks can be straightened out before a meltdown. Without 
these answers an informed order to evacuate cannot be made. 



Reconmiendatlons : 



1) A diligent effort must be made to Identify all persons within the EPZ 
who may need transportation assistance in an evacuation due to physical 
disability. 

2) Practical plans must be developed to provide prompt transportation for 
each individual needing assistance to evacuate. 

3) Civil defense officials should meet with the administrators of all 
nursing homes, medical facilities, campgrounds and correctional facilities 
to develop workable evacuation plans for the residents and the staff and to 
Identify specific transportation needs for each institution at various times 
of the day, week and year. 

4) Civil defense officials should sit down with school administrators and 
the P.T.A. to develop workable student and teacher evacuation plans and 
establish criteria for determining when, if ever, it would be appropriate 
to send children home first to evacuate with their families. 

5) Civil Defense should undertake a comprehensive study, financed by 
Boston Edison, of public transportation resources available at various 
times of the day, week and year. Written agreements should be reached with 
both transport companies and their bus drivers. 



199 



33 - 



Reception Facilities 

If any evacuation is ordered, TV and radio EBS broadcasts and the 
police will direct evacuees to designated "reception centers" outside the 
EPZ. Evacuees will be monitored for radiation and decontaminated (if 

necessary), re-united with family members, and assigned shelter and/or 

43 
transportation. There are numerous problems with the feasibility and 

safety of the proposed reception procedure. 

The first and most glaring problem is the location of the reception 

centers. Two of the three centers are in exactly the same direction as 

44 
the areas from which evacuees would be fleeing! If the wind were blowing 

northward during an accident, evacuees north of Pilgrim would be sent 

north to Hanover Mall, just 20 miles downwind from Pilgrim. Government 

figures, remember, estimate a "worst-case" accident could cause deaths 

20 miles downwind from the plant. Bridgewater State College has the same 

problem since it is located 20 miles due west of Pilgrim. Taunton State 

Hospital, the reception center for southern evacuees would also be within 

the radioactive plume if the wind were blowing southwest. If is unlikely 

in any case that most evacuees would stop just 20 miles downwind of a 

nuclear meltdown. 

A summer evacuation would send roughly 40,000 people to any of these 

45 
reception areas. No one could seriously contend that any of these recep- 



tion centers could handle that many people within the federal guideline of 

46 
12 hours. During the March 3, 1982 drill, FEMA reported that Hanover 

officials "questioned whether water and sewage facilities were adequate for 



200 



- 34 



47 
potentially large numbers of people." Hanover Mall does not even 

have adequate facilities for a few thousand people, let alone 40,000, 

The State Plans provide for decontamination of evacuees and their 

48 
vehicles. Several decontamination washing solutions are recommended 

for a range of body and vehicle surfaces and degrees of contamination. 

The plans caution that decontamination wash "drainage must be controlled." 

Current reception centers do not stock the recommended wash solutions, 

nor is there provision for control of contaminated drainage. FEMA 

criticized the lack of "soap, waste disposal, and contaminated clothing 

bags" at the centers. 



Recommendations: 



1) New reception centers should be established at least 40 miles from 
Pilgrim, north and west of Boston. 

2) These should be adequate to accommodate the entire permanent and 
transient population in the EPZ. 

3) Each reception center should stock the full range of recommended wash 
solutions and have the capability of collecting contaminated wash 
drainage. 



201 



Medical Facilities 

A core meltdown could result in a significant release of radioactive 
gases and particulate matter into the air. This can cause genetic mutations, 
cancer, serious injuries, and even death to all life forms. For this 
reason, federal regulations mandate the provision of special medical care 
for contaminated injured indl .-iduals . The only two hospitals listed as 

providers of any medical care, however, admit they have the capacity to 

52 
treat only 8 or 9 contaminated persons. One of these hospitals, moreover, 

is only 3*1 ailea from the plant and obviously should not be utilized. 

The remaining hospital has no staff trained for radioactively contaminated 

53 
patients. 

As a suppleuBnt to treatment at medical facilities — but by no means 

a substitute — potassium iodide (KI) has been proven safe and effective 

54 
against radioactive iodine as a means of preventing thyroid tumors. 

Laboratory workers exposed to radioactive iodine have taken KI for many years 
and FEMA guidelines now call for the use of KI in the event of a nuclear 
accident. ^^ It is distributed by the Tennesse Valley Authority to house- 
holds near the Sequoyah reactor and throughout all EPZ's In Sweden. 
National public interest organizations including the Union of Concerned 
Scientists and the Health Research Group support the distribution of KI to 

all dwellings in the EPZ and it's availability for sale over-the-counter 

56 
for summer residents and those just outside the EPZ. 



202 



- 36 - 



Recommendations: 



1) Sufficient medical facilities outside the EPZ should be Ide 
to care for large numbers of contaminated individuals. 

2) All emergency personnel should receive special training in 
treatment of radiation victims. 

3) Potassium iodide should be distributed in childproof contai 
to every household in the EPZ before a nuclear accident. Inatr 
should be included and the substance should be sold over-the-co 
as well. 



Sheltering 

If there is inadequate time to evacuate the public before . 
of radiation passes through an area, the recommended protective i 
shelter ing.^^ As the cloud blows downwind, some of the radloact 
material or "fallout" is deposited on the ground and buildings I 
If a substantial amount of fallout were deposited by the radioac 
cloud, then evacuation would be ordered as soon as the cloud pa; 
order to minimize additional radiation exposure. 

An effective sheltering strategy requires both protection i 
gamma radiation emitted from the passing radioactive cloud and f 
fallout as well as protection against inhalation of airborne rac 
particles. The basements of large buildings and of brick homes 
most protection from gamma radiation. ^^ But where are 45.000 su 
tourists going to find basements in large buildings or brick horn 



203 



37 - 



Wooden motels and cabins and tents provide virtually no sheltering 
protection from a radioactive cloud, and the 24,000 sufflmer residents 
typically live In cottages that are also wooden and without basements. 

In fact, even for the 54,000 full-time residents, there are few 
large buildings or brick homes with basements In the Pilgrim EPZ. Fewer 
than 20Z of the permanent residences In Massachusetts are brick , and 
about 30Z of the year-round homes In the EPZ have no basement. Con- 
sequently # a substantial majority of the people in the EPZ lack adequate 
sheltering facilities. 

Civil Defense has still not completed a survey of available public 

shelters in the EPZ. Those shelters identified already are not marked 

62 
on evacuation maps as required by federal guidelines. 

This lack of sheltering protection is compounded by the failure to 

educate the public about simple building infiltration and breathing filter 

techniques. Sheltering studies have revealed that an average residence 

with windows and doors shut reduces the amount of radionuclides inhaled 

by about 35Z. Greater protection is afforded by weatherstripping, storm 

windows and doors, and the taping of all window and door cracks in an 

emergency. Further protection would be provided by the use of individual 

respiratory filters such as hospital masks or wet towels or handkerchiefs. 

The Emergency Public Information pamphlet, however, makes no mention of 

these Important protective measures. 



204 



- 38 



Recommendations : 

1) Civil Defense should identify enough public shelters to accommodate 
as many as 80,000 people who lack basements in the summer. 6* 

2)* Public sheltering facilities should be equipped with necessities and 
clearly marked as Civil Defense shelters. Large signs should be erected 
directing tourists to the nearest shelters. 

3) The location of public sheltering facilities should be clearly 
designated on the maps in the Emergency Public Information brochures, 
on large posters and in telephone book inserts distributed throughout 
the EPZ. 

4) All emergency public Information materials should include 
sheltering instructions, including techniques for making home-made 
breathing filters and reducing radioactive air infiltration into 
sheltering facilities or homes. 

5) Civil Defense should distribute hospital masks to every building in 
the EPZ. ^5 



205 



- 39 



Emergency Drills 

No planB with the complexity of evacuation plans could ever be 
carried out successfully without regular and comprehensive drills. Every 
year, Boston Edison and state officials hold an emergency exercise 
simulating a meltdown at Pilgrim. The exercises expose liqjortant defi- 
ciencies which must be corrected, but they are still not sufficiently 
coi)H)rehen8lve to verify the capability to protect the public in the event 
of an actual meltdown. 

At last year's drill, FEMA identified many deficiencies, including 
inoperable sirens, failure to activate an emergency broadcast system 
station, lack of equipment for measuring radiation, and the Issuance of 
an Incorrect evacuation order. The federal evaluation of this year'a 
drill, held June 29, will not be completed for several weeks, but Civil 
Defense and FEMA observers admitted there were significant comminicatlon 
problems at least. The troubled siren system will not be tested until 
FEMA Issues new evaluation criteria later this year. 

A more serious problem la the failure of the exercises to dencnstrate 
the capability to warn, mobilize, evacuate, and decontaminate the public. 
Even FEMA has conceded this point. It is not necessary to attempt a 
full-scale public evacuation to establish this capability. At a minimum, 
however, all sirens should be tested, sample messages broadcast on EBS, 
special institutions alerted and transportation arranged for all special 
population groups needing assistance within the sector targeted for 
evacuation. This is an excellent occasion to educate the public through 
the media of the details of sheltering and evacuation. 



206 



- AO - 



Another problem with the exercises Is the comprehensive prior 
planning and prenotif ication of emergency personnel. Federal criteria 
require occasional unannounced exercises during the evening and night- 
time and under various weather conditions which more accurately test the 
real emergency response capability of officials. 

Recommendations: 



1) Emergency exercises should include every aspect of an actual emergency 
response, except evacuation of the public. Every drill should include 
testing of all sirens, institutional alarms and back-up warning capability; 
activation of the EBS system and broadcast of simulated emergency messages, 
arrangements for transportation for all special population groups within 
the sector targeted for evacuation, and bringing in some buses from each 
participating bus company to report to a special institution or staging 
area and then to drive the evacuation route to the appropriate reception 



2) Drills should be conducted in the evening, at night, under various 
weather conditions and seasons, and without prior warning. 



207 



41 



CONCLDSION 

Individually, jmy of the problems with current emergency planning 
Identified in this report is serious; collectively, they point to a 
crisis situation in extreme proportions. Even the Director of the 
Plynouth Civil Defense office, James Ryan, has admitted "there is no 
way that everyone can be evacuated." 

Besides the indefensible danger presented by the emergency plane, 

2 
violations of state and federal law are involved. The plans are required 

to provide "reasonable assurance that adequate protective measures can 

and will be taken in the event of a radiological emergency." The 

Massachusetts Attorney General has agreed that the current plans fail to 

do this and has urged that consideration be given to the operation of 

Pilgrim at reduced power or even shut down during the summer, when the 

3 
area is clogged with visitors whose lives are in jeopardy. 

MASSPIRG has submitted a formal petition to the Nuclear Regulatory 

Commission requesting immediate remedial measures, including consideration 

of shutting down Pilgrim until an adequate state of emergency preparedness 

- 4 
is achieved. Given the NRC's recent refusal to enforce emergency planning 

regulations under similar conditions at the Indian Point reactors in 

3 

New York , though, it will no doubt fall to the Conmionwealth to protect 

its citizens. MASSPIRG therefore urges the Governor to establish a public 
emergency planning commission to oversee the revision of these plans for 
Pilgrim (and for the area near the Rowe reactor, to the extent its problems 
are similar). The state also should commission an emergency mass transpor- 



208 



42 



tatlon study, a new calculation of evacuation time estimates, and a 
computer analysis of the consequences of major meltdowns with an eye 
to expanding the emergency planning zone to Include Cape Cod and 
other areas near the Plymouth plant. Until these recomnwndatlons are 
Implemented — until the egregious Inadequacy of current planning is 
acknowledged and corrected — the lives of thousands of citizens will 
remain at risk. 



! 



209 

- 43 - 

FOOTNOTES 
OVERVIEW 

1. MASSPIRG Survey of Major Campgrounds, Appendix B. 

2. "Interim Findings: Joint State and Local Radiological Emergency Response 
Capabilities for the Pilgrim Nuclear Power Station" ("FEMA Interim Findings") , 
FEMA, September 1982. 

3. "Planning Basis for the Development of State and Local Government Radiological 
Emergency Response Plans in Support of Light Water Nuclear Power Plants," 
("Planning Basis"), mJREG-0396, EPA/NRC. December 1978, p, 20. Also see 
Chapter IV: Evacuation Plans . 

4. See Chapter IV: Sheltering . 

5. "Three Mile Island: Report to the Commissioners and to the Public" ("NRC 
Special Inquiry Group Report"), NRC Special Inquiry Group, 1980, p. 132. 

6. "Report of the President's Commission on the Accident at Three Mile Island" 
("Report of the President's Commission"), October, 1979, pp. 76-77 (emphasla 
in original); NRC Special Inquiry Group Report, op. cit . pp. 131-133. 

7. The NRC defines a "worst-case accident" as the worst accident considered 
theoretically possible at a nuclear power plant. It may be worth noting, 
however, that the accident at Three Mile Island was considered "not credible" - 
which is to say, impossible - before it actually happened. 

8. "Calculation of Reactor Accident Consequences ("CRAG 2") For U.S. Nuclear 
Power Plants (Health Effects and Costs) Conditional on an SSTI Release," 
U.S. House of Representatives Committee on Interior and Insular Affairs, 
Subcommittee on Oversight and Investigations, November 1, 1982, p. 9. 

9. NRC Special Inquiry Group Report, op. cit ., p. 91. 

10. "Precursors to Potential Severe Core Damage Accidents" ("Precursors"), 
NUREG/CR-2497, Oak Ridge National Laboratories, 1982. 

11. Report of the President's Coimnission, op. cit ., p. 7. 

12. "PrecuTBors," op. cit . 

13. "Systematic Assessment of Licensee Performance," NUREG-0834, 1981; 
NRC memo from Gus Lalnas, Assistant Director for Safety Assessment, to 
Darrell Elsenhut, Director, Division of Licensing, "Summary of the 
Operating Reactor Events Meeting on December 16, 1981 ," December 28, 1981. 
(These safety rankings are based on both the number and severity of mishaps 
between December 13, 1980 and October 7, 1981. 

14. Letter to F.M. Staszesky, President, Boston Edison Company from Richard C. 
DeYoung, Director, NRC office of Inspection and Enforcement, NRC Docket 
No. 50-293 (January 18, 1982). 

15. NRC SEeclal Inquiry Group Report, op. cit ., p. 131. 



210 



44 - 



'16. Roport of the President's Commission, op. cit ., p. 76. 

17. 10 CFR §50.47 and Part 50, Appendix E. 

18. 10 CFR i50.54(s)(2)(i). 

19. 44 CFR §350. 5(b) (proposed rule; current FEMA guidelines); 
10 CFR §50.4:(a)(l). 

20. 10 CFR §50. 47(c)(1). 

21. "In the Matter of Consolidated Edison Company of New York and 
Power Authority of the State of New York (Indian Point 2 & 3)", 
CLI-83-16, June 10, 1983. 

22. "Interim Findings," op. cit ., pp. 1,5. 



I. THE EMERGENCY PLANNING ZONE 

1. 10 CFR §50. 47(c)(2) ; 44 CFR 8350. 7.(b) (current guidelines). 

2. Planning Basis, op. cit . ; "Massachusetts Radiological Emergency Response 
Plan ("State Plan")," Appendix 3 - Pilgrim, pp. C-78-79. (The Environmental 
Protection Agency recommends evacuation when the expected radiation dose to 
the public is one "REM". A REM is a unit of measuring radiation exposure 
and is the equivalent of receiving about 10 x-rays.) 

3. Planning Basis, op. cit . 

4. "CR/-.C 2," op. cit . 

5. Report of the President's Commission, op. cit ., p. 40. 

6. "Emergency Planning Zones for Serious Nuclear Power Plant Accidents," 
California Office of Emergency Services, November 1980. 

7. The Planning Basis report, op. cit ., was written in 1978 and used the 
probability estimates of the 1975 Reactor Safety Study. More recent 
studies indicate a higher probability of accidents (Precursors, op. cit .) 
and more serious consequences from them (CRAC 2, op. cit .). 

8. "Planning Basis," op. cit ., p. 16. 

9. "Response of Boston Edison to Commonwealth of Massachusetts' First Set of 
Interrogatories on Emergency Planning, " July 20, 1981, p. 2. 

10. "NRC Special Inquiry Group Report," op. cit ., p. 1016. 

11. "A Public Meeting on the State and Local Off-Site Radiological Emergency Plan,' 
Transcript of Hearing. ("Transcript of Public Hearing"), Plymouth, Mass., 
June 3, 1932, statement by Baul Cahill, then Director. Mass. Civil Defense 
Agency, p. 109. 



211 



45 



12. "Comments of Attorney General Francis X. Bellottl Relative to Off-Site 

Emergency Planning for the Pilgrim Nuclear Power Station," ("Coainents of the 
Attorney General"), submitted to FEMA, August 1982, pp. 11-13. 



II. ADVANCE INFORMATION TO THE PUBLIC 

1. "The Social and Economic Effects of the Accident at Three Mile island," 
C.B. Flynn and J. A. Chalmers, 1980, p. 22. (About 20,000 people evacuated 
from Three Mile Island before any order was Issued.) On the other hand, the 
MASSPIRG Survey also revealed that 7Z of respondents would not evacuate 
even if ordered to do so (Appendix A, l?32). Twenty percent of respondents 
in the Shoreham EPZ said they would not evacuate. ("Discussion Overview 

of the RERP of the County of Suffolk," Philip B. Herr & Associates, 
Nov. 29, 1982, p. 15.) 

2. Criteria for Preparation and Evaluation of Radiological Emergency Response 
Plans and Preparedness In Support of Nuclear Power Plants ("Evaluation 
Criteria"), NUREG-0654, Rev. 1, Evaluation Criteria G. 1. ,G. 2. 

. 3. Evaluation Criterion G.l. 

'4. State Plan, op. cit ., p. C-9. 

. 5. FEMA Interim Findings, op. cit ., p. 6. 

6. Phone conversation with Gerald Hayes, former Plynouth Civil Defense Director. 
July 12, 1982. 

7. MASSPIRG Survey of Residents, Appendix A, l?23, )?28. 

8. MASSPIRG Survey of Residents, Appendix A, //16, 

9. Nuclear Energy - Questions and Answers, p. 4. 
■10. MASSPIRG Survey of Residents, Appendix A, #43. 

11. MASSPIRG Survey of Residents, Appendix A, #32 

12. Town of Plymouth Radiological Emergency Response Plan ("Plynouth Plan"), p. 36. 
Emergency Public Information, p. 6. 

13. Plymouth Plan, op. cit ., p. ANN. B-9. 

14. MASSPIRG Survey of Local Civil Defense Directors, Appendix C. 

15. MASSPIRG Survey of Correctional Facilities, Appendix D; Interim Findings, 
op. cit ., pp. 15-16. 



16. 



MASSPIRG Survey of Local Civil Defense Directors, Appendix C. 



212 



46 - 



17. ' MASSPIRG Survey of Local Civil Defense Directors, Appendix C. 

18. FEMA Interim Findings, op. cit ., p. 6; Evaluation Criterion P. 10. 

19. State Plan, op. cit ., p. C-21. 

20. Evaluation Criterion G.2. 

III. NOTIFICATION DURING AN ACCIDENT 

1. "Planning Basis," op. cit ., p. 20. 

2. Letter from Richard Starostecki, Director, Division of Project and Resident 
Programs, NRC, to Boston Edison, dated Septeniber 28, 1982, Appendix A: 
Notice of Violation. 

3. 10 CFR Part 50, Appendix E, IV, D.3. 

4. Evaluation Criterion E.6. and NUREG-0654, Appendix 3, p. 3-3. 

5. Report on the Coverage and Performance of Sirens Around the Pilgrim 
Nuclear Pover Station ("HUM Siren Report") , HUM Associates, July 15, 1982, 
pp. 2-6 - 2-7. 

6. Report on the Pilgrim Nuclear Power Station Siren Test, June 19, 1982 
("FEMA Siren Report"), FEMA, January 1983, p. 6. 

7. HMM Siren Report, op. cit ., pp. 8-3, 4-7. 

8. FEMA Siren Report, op. cit ., pp. 11, 10. 

9. MASSPIRG Survey of Residents, Appendix A, ff7 , (?13. 

10. FEMA Siren Report, op. cit ., p. 11. 

11. Letter from Lee Thomas, Acting Deputy Director, FEMA, to William Dircks, 
Executive Director for Operations, NRC, dated December 17, 1982. 

12. FEMA Siren Report, op. cit ., p. 9. 

13. MASSPIRG Survey of Residents, Appendix A, HS, 1119. 

14. FEMA Siren Report, op. cit ., p. 8. 

15. MASSPIRG Survey of Residents, Appendix A, 1116. 

16. MASSPIRG Survey of Residents, Appendix A, l?29. 

17. MASSPIRG Survey of Correctional Facilities, Appendix D, 



213 



47 - 



18. FEMA Interim Comments, op. clt .. p. 15. 

19. Evaluation Criteria E.5, E.6. 

.20. Transcript of Public Hearing, June 3. 1982, pp. 79-86. 

21. FEMA Exercise Report, op. clt. , p. 54. 

22. 7% (:59,000 deaf and 335,000 with serious hearing impairments out of 
5,737,037 total residents) of Massachusetts residents have serious 
hearing deficiencies. Although deaf people tend to congregate in urban 
areas, it is reasonable to estimate that 2Z (54,000 permanent residents 
in EPZ) or 1000 residents have serious hearing problems in the EPZ. 

23. Criteria J.lO.c, E.6. ; 10 CFR Fart 50, Appendix E, IV. D. 3. 

24. State Plan, op. clt ., p. C-24. 

25. State Plan, op. clt ., p. C-24 - C-25. 

26. Teletypvriters (TTY's) transmit typewriter messages over phone lines 

with warning lights that signal receipt of a message. In the past, Boston 
Edison offered to provide TTY's to deaf persons in the EPZ. California 
has provided TTY's to all deaf persons In the state. 



IV. EVACUATION PLANS, SHELTERING, AND OTHER PREPARATIONS 

1. Plymouth Plan, op. clt ., pp. 5-6. 

2. NUREG-0654, p. 17. 

3. "An Evaluation of the Evacuation Time Estimates Submitted by the Applicant 
for a Peak. Population Scenario at the Pilgrim II Nuclear Power Station," 
E.P, Moeller, T. Urbanlk II, and A.E. Desrosiers. March 1981, p. 5. 

4. State Plan, op. clt ., p. C-86 (South 10 Miles - Normal Weather). 

5. "Evacuation from a Nuclear Technological Disaster," D.J. Zlegler, S.D. Brunn 
and J.H. Johnson, Jr., The Geographical Review , January 1981, p. 7. 

6. "Seabrook Station Evacuation Analysis," ("Seabrook Analysts'!) Voorhuis and 
Associates, August 1980, p. 63. 

7. Seabrook Analysis, p. 74; "Dynamic Evacuation Analyses: Independent 
Assessments of Evacuation Times from the Plume Exposure Pathway Emergency 
Planning Zones of Twelve Nuclear Power Stations," FEMA-REP-3, 1981, p. 46. 



214 



- 48 - 

8. Exercise Report - Joint State and Local Radiological Emergency Response 
Exercise for the Pilgrim Nuclear Power Station, March 3, 1982 ("FEMA 
Exercise Report"), FEMA, Septerier 1982, p. 45. 

■ 9. Evaluation Criteria J. 8., J. 10.1., and Appendix U, pp. 4-3, 4-6, 4-7, 4-9, 4-10. 

10. State Plan, op. cit. , p. C-86. 

11. "Comments of Attorney General Francis X. Bellotti Relative to Off-Site 
Emergency Planning for the Pilgrim Nuclear Power Station" ("Comments of the 
Attorney General"), submitted to FEMA, August 1982, pp. 7-9,. 

12. Plymouth Plan, op. cit. , p. 8. 

13. MASSPIRG Survey of Residents, Appendix A, #34. 

14. Town of Plynouth Planning Board Survey, 1979; MASSPIRG Survey of ReBidents, 
Appendix A, #6. 

15. Emergency Public Information Pamphlet, p. 6. 

16. FEMA Exercise Report, op. cit. . p. 45. 

17. Evaluation Criteria A.3. andC.4. 

18. To evacuate 14,000 people in buses with a capacity of 40 persons would 
require about 350 buses. Evacuation buses would not have room for much more 
than their capacity of 40 people because evacuees are directed to bring extra 
clot. ling and necessities. The civil defense estimate that only about 

50 buses would be needed is clearly inadequate [FEMA Exercise Report, p. 45]. 
Civil defense also relies on carpooling too much [Plymouth Plan, p. 8], 
There simply won't be that much extra room In the family car after the family, 
pets and clothing are stuffed into cars which are becoming smaller and smaller. 

19. "Response of Emergency Personnel to a Possible Accident at the Shoreham 
Nuclear Power Plant," Social Data Analysis, Inc., October 1982; "Update 
Report on the Status of Remedial Actions Cited in the July 30, 1982 Interim 
Findings on the Adequacy of Radiological Emergency Rebponse Preparation of 
State and Local Governments at the Indian Point Nuclear Power Station," 
("Update Report on Indian Point,"), December 1982, p. 6. 

20. Evaluation Criterion J.lO.d; The MASSPIRG Survey of Residents discovered that 
6X of households in the EPZ had physically disabled people. 62 of 20,000 
households in the EPZ (1980 Census) is 1200 handicapped persons. 

21. State Plan, op. cit. , pp. 22-23. 

22. Plymouth Plan. op. cit. , pp. 39-40. 

23. MASSPIRG Survey of Ambulance Services, Appendix E. 

24. MASSPIRG Survey of Ambulance Services, Appendix E. 



215 

- 49 - 

25. FEMA Interim Findings, op. cit. . p. 6. 

26. MASSPIRG Surveys of Nursing Homes (Appendix F) , Campgrounds (Appendix B) 
and Correctional Facilities (Appendix D). 

27. Plymouth Plan. op. cit. . p. 38. 

28. Plymouth Plan, op. cit. . p. 36. 

29. Emergency Public Information pamphlet, p. 6. 

30. MASSPIRG Survey of Nursing Homes, Appendix F. 

31. Conversation with Frank. Willard. the Director of MCDA Area II Headquarters 
in Bridgewater, February, 1983. 

32. Plymouth Plan, op. cit .. p. 39; Emergency Public Information pamphlet, p. 6. 

33. MASSPIRG Survey of Correctional Facilities, Appendix D. 
3A, FEMA Exercise Report, op. cit. . p. 25. 

35. Update Report on Indian Point, p. 6. 

36. MASSPIRG Survey of Campgrounds, Appendix B. 

37. Conversation with Frank Willard, Director of MCDA Area II Headquarters in 
Bridgewater, May, 1983. 

38. Transcript of Public Hearing, June 3, 1982, Statement by Paul CahlH, former 
Director of the Mass. Civil Defense Agency, p. 109. 

39. Conversation with Jane Peterson, Cape Cod Chamber of Commerce, February 8, 1983, 

40. See Chapter I, supra , p. 7. 

41. Warning sirens are only located within the 10-mile EPZ. 

42. US Census, 1970 (basement data not collected in 1980 census). 

43. State Plan, op. cit .. pp. C-17 - C-19; Annex E, pp. C-101 - C-113. 

44. State Plan, op. cit. . p. C-17. 

45. Total summer population of the EPZ is about 120.000, divided among 3 reception 
centers results in roughly 40,000 evacuees per reception center. 

46. Evaluation Criterion J. 12. 

47. FEMA Exercise Report, op. cit .. p. 31. 

48. State Plan, op. cit .. Annex E. C-102 - C-103. 

49. State Plan, op. cit .. C-70 - C-72. 



216 



-so- 
so. FEMA Interim Findings, op. clt .. p. 9. 

51. 10 CFR § 50.47(b) (12); 10 CFR Part 50, Appendix E, II. E and IV. E. 7. 

52. MASSPIRG Survey of Hospitals, Appendix G. 

53. MASSPIRG Survey of Hospitals, Appendix G. 

54. 43 Federal Register 58798, December 15, 1978. 

55. Evaluation Criterion J. lO.e. and J.lO.f. 

56. "Submission for the Record: Hearing on Potassium Iodide as a Thyroid Blocking 
Agent in a Radiation Emergency," Gordon Thompson, Ph.D., Union of Concerned 
Scientists, submitted to the U.S. House of Representatives Committee on 
Interior and Insular Affairs, Investigations and Oversight Subcommittee, 
March 5, 1982. The Mass. Department of Public Health opposes distribution 

of KI to the public. The advantages of KI far outweigh the disadvantages. 
None of DPH's arguments against use of KI override the protection that KI 
can provide from radiation exposure. 

The logistical problem of distributing KI after an accident has been solved by 
the Tennessee Valley Authority by simply distributing proper doses of the 
drug to residents within the EPZ before a meltdown occurs. The directions 
will indicate the dose and emergency officials will announce when to take 
the KI. Childproof caps would prevent unsupervised Ingestion by kids. 

The side effects anticipated from the recommended dosage for radloprotectlon 
will be very minimal. Side effects occasionally appear after years of KI 
use at doses of 300 mg to 1200 mg per day. But for radiation protection, 
adults would take only 130 mg per day . for 10 days, and kids Just 65 mg per 
day. 

A few recent studies have suggested that anticipated releases of radioactive 
iodine during a reactor accident may be much lower than originally expected. 
The NRC, however, conducted a substantial investigation in 1981 that concluded 
that although the Reactor Safety Study may have overestimated the iodine 
that would be released from small accidents, the original estimates are 
probably still valid for the larger accidents. ["Technical Bases For 
Estimating Fission Product Behavior During LWR Accidents," NUREG-0772, 
June, 1981.1 

The last issue concerning KI is whether stockpiling the drug for distribution 
during an accident would be preferable to predistributing KI to all households 
in the EPZ. Attempting to distribute KI to all potentially affected households 
after an accident began would be a logistic nightmare if not physically impossible 

57. Plymouth Plan, op. clt., pp. 5-6. 

58. "Public Protection Strategies for Potential Nuclear Reactor Accidents: 
Sheltering Concepts with Existing Public and Private Structures," (SAND77-1725 
D.C. Aldrich, D.M. Erlcson, Jr., J.D. Johnson, Sandla Laboratories, 1978, 

p. 10. 



217 



51 



59. Population figures are from the State Plan, op. clt. , p. C-9. 

60. SAND77-1725, p. 26. 

61. 1970 Census Data (basement data not collected in 1980). 

62. Evaluation Criterion J. 10. a. 

63. "Public Protection Strategies In the Event of a Nuclear Reactor Accident" 
(SAND77-1555) D.C. Aldrich, D.M. Ericson, Jr.. Sandia Laboratories, 1978, 
pp. 40, 42-43. 

64. There are 45,000 tourists on summer weekends. There are 24,000 seasonal 
residents of which close to 20,000 probably have no basement in their 
cottages. 30Z of the 54,000 permanent residents don't have basements 
about 15,000 people. 

65. 100,000 hospital masks for distribution in the EPZ would cost $19,090 
from American Scientific Products, according to sales representative Mike 
Govern. (Centura Mask - 685-N) 

66. FEMA's Interim Findings, op. cit. , pp. 15,17.18; Exercise Report, op. clt. , 

p. 54. 

67. Conversation with Bob Archlla, FEMA, July 13, 1983. 

68. FEMA's Interim Findings, op. cit. , p. 18. 

69. Evaluation Criterion N.l.b. 

70. Buses drive actual evacuation routes during drills for the Indian Point 
reactors, "Post Exercise Assessment (Indian Point)," FEMA, April 14, 1983. 
p. 14. 



CONCLUSION 

1. MASSPIRG. Survey of Civil Defense Directors, Appendix C. 

2. The failure to maintain adequate emergency response plans for a nuclear 
accident is a violation of the Mass. Civil Defense Agency's responsibility 
to protect the citizens of the Commonwealth. Mass. General Laws, Appendix 
to Chapter 33, Section 13. Federal law also requires workable plans: 

10 CFR 8 50.47(a) (1)(NRC) and 44 CFR g 350.5(b) (FEMA) . 

3. Comments of the Attorney General, op. cit. , pp. 1, 14-15. 

4. Petition of Massachusetts Public Interest Research Group for Emergency and 
Remedial Action, July 18, 1983. 

5. "In the Matter of Consolidated Edison Company of New York and Power Authority 
of the State of New York (Indian Point 2 & 3)," CLI-83-16, June 10, 1983. 



218 



APPENDIX A 

MASSPIRG Survey of Residents in the Emergency Planning Zone 

MASSPIRG conducted a telephone survey of 100 residents of the 
Emergency Planning Zone (EPZ) . The survey was designed and supervised 
by Martha Downey of Decision Research Corporation of Lexington, Mass, 
Respondents were selected at random from local telephone books for 
Plymouth, Duxbury, and Kingston. The number of respondents from each 
town was determined by the populations of each town so the results are 
applicable to the full EPZ, (Plymouth (pop. 35,913): 64 respondents, 
Diixbury (11,807): 22 respondents, and Kingston (7,362): 14 respondents), 
Half the respondents from each town were men and half women. MASSPIRG 
volunteers conducted the survey between February and May, 1983. 



219 



Telephone Survey of 100 Raaidencs In the Eaergency Planning Zone: Sunaiery of Reeulcs 
Queedon 



1. Local fire response capability? 



2. Quality of fire personnel and 
equipment? 



Anbulance response capability? 



^> Quality of anbulance personnel 
and equlpnent? 



5. Work Indoors at office or building 
other than your residence? 

(If "no" or "unsure" proceed to #8) 



6. Where Is office or building 
located? 



Hear sirens when at work with 
windows and doors closed? 



8. Hear sirens at residence with 
windows and doors closed? 



9. Aware of any other public 
emergency warning systems? 



Very Good 

Good 

Fair 

Poor 

Unaure 

Very Good 
Good 
Fair 
Poor 

Unsure 

Very Good 

Good 

Fair 

Poor 

Dnsure 

Very Good 
Good . 
Fair 

Poor 
Unsure 

Tea 

Ho 
Unsure 

Kesldence 

Plyscuth, 
Dux., King 

Outside 
EFZ 

No Job/ 
Unsure 

Yes 
No 

Unsure 

Yes 
Ho 

Unsure 

Pilgrim 
Other 
No 
Unsure 



Plysuuth Kingston Duxbury 

64 Respondents U Res. 22 gas. Totsl 



24 

26 

2 

1 

II 

27 

21 

4 



12 

21 

22 

4 

1 

16 

12 

21 

7 



24 

32 

32 



12 
4 

10 
7 

12 

U 

1 

53 

11 


55 
2 
5 

8 



5 
5 




4 

5 
7 


2 

5 
5 
1 

3 

3 
6 
2 

3 

9 
5 


2 
2 
3 
1 

3 
1 


13 
I 


12 

2 
1 



11 
7 


4 

8 
8 


6 

14 
3 


5 



u 


26 


3 


30 





9 








8 


35 


13 


54 


9 


46 








I 


15 


4 


10 


8 


21 





8 


3 


18 


4 


16 


1 


2 


17 


83 


2 


14 


I 


1 


20 


87 


I 


3 


1 


8 


4 


13 



40 

38 

2 

1 

19 

40 

36 

4 



20 

40 

30 

5 

1 

24 



220 



Talephon* Survay of 100 Xesldants In ch« 
Qu««tlon 



crgcncy Planning Zon«; 



Sui 



■ry of Xtculta 



10. If ooc, aware of the Pilgrim 
warning? 



II. What doea the Pilgrim siren 
mean? 



Plymouth Xingaton Duxbury 

<* Raapondenta 14 Raa. 22 Rea. Total 



12. Ever heard a Pilgrim warning 
alren from home or job? 

(If "no" or "unsure" proceed 
to #16) 



13. Can the Pilgrim alren be heard 
veil when vlndowa and doors 
art closed? 



T«s 

Ho 
Unsure 

Accident 
or warning 

Drill or 
test 

Malfuncxion 

Other 

Unsure 

Home 

Job 

No 

Unsure 



(Home) 



Well 

Not well 
Not at all 
Unsure 





(Job) 


Well 


1 






Not well 


2 






Not at all 


4 






Unsure 


1 


u. 


Know location of nearest 
siren? 








(Home) 


Yes 


40 






No 


" 






Unsure 


3 




(Job) 


Yea 


3 






No 









Unsure 


1 



IS. How far Is the alren? 
(Home) 



<l/2 mile 

between 1/2 mile & 1 nile 

>1 mile 

Unsure 

Reaponse not credible 



27 

2 

21 

1 

8 

49 
4 

12 




27 

19 

7 





26 

10 

7 



10 



1 


2 


1 





2 


1 


1 


4 


12 


16 


3 





2 


4 





2 



15 



8 


10 


3 


3 


1 


2 





2 


3 





1 








1 





I 



7 


12 


5 


6 





1 


2 


3 


1 












221 



TtXcphen« Surwy of 100 Htddaacs la th* Eacrgaacy Planning Zona: Suanary of ILaaulta 



Quaatlon 



Plyaouth Klngiton Duxbury 

6* Kaapondanta U Kaa. 22 Rai. Total 



22. 



15. (continued) 

Row far la tha a Iran? 



(Job) ^1/2 Bila 

batwaan 1/2 mIIc ( 1 idla 

> 1 Blla 

Unaure 

Reaponaa not credlbla 



16. First reaction to Pilgrim alrcn. 
If not drUlT 



Evacuate 
Shcltar 
Radio or T.V. 
Eaerifancy Broadcast Syatea atatlon 

Ignore 

Unaura 

Teat or aalfunctlon 

Call police 

other 



17. Can you naaa an Ea«rgency Broadcaat 
, Syataa station? 



18. Ever heard Pllgrla alran go off 
accidentallyT 

(If "no" or "unaura" proceed to 120) 



Yea 

Ho 

Yea 

Ito 
Unaura 



19. How aany tlaaa? 



1 

2 

3-7 

8 or Bore 

Call soaeone 

Radio or T.V. 

Other 

Unaure 

Great deal 

Sone 

Not Buch 

None 

Unsure 



How did you learn what you know Media 

about emergency procedures? „.,. . , . . 

" Official Brochure 

Word of Bouth 

Other 



20. How would you determine whether a 
alren was a falaa alar«7 



21. How much do you feel you know 
about eacrgency procaduree In 
case of an accident at Pilgrim? 



1 


I 


5 
5 

12 

6 
10 
12 

7 

6 

3 

40 
2* 

51 
9 
1 

8 

7 

2S 

9 

19 

28 

9 

10 

4 
19 
28 
II 

1 

19 
24 
.7 
14 




3 
7 
I 

2 
8 

1 
3 


3 
8 

3 



s 

3 

1 

4 



10 



3 

2 
1 
1 


7 

7 
19 

9 
17 
17 
13 

7 



59 
41 

77 

18 

2 

10 
15 
39 
11 

29 
46 
11 
17 

6 
29 

44 
16 

4 

32 
35 

11 
21 



222 



Ttlcphon« Survay of 100 Kaddcnti In ch« Energcncy Planning Zone: Suarury of Raiulcs 
Qu«»tlon 



Plyaouch Kingston Duxbury 

64 Ke«pond«nti U R««. 22 Res. ^ot») 



23. Haim you received Emergency Public 
Informadon Brochure? 

(If "no" or "unsure" proceed to *29) 



29. 



24, 



When? 



25. Did you read the brochure? 



26. Was It helpful? 



27. Do you have the brochure 
available right now? 



28. Where is It kept? 



Any questions regarding 
emergency planning? 

* The response of one Plymouth man was 
"Why can't they ia^rove the sirens so 
people uould believe them?" 



30. Dangerousness of accident at Pilgrim? 



Yes 


45 


No 


16 


9) Unsure 


Z 


Sept "82" 


3 


Oct "82" 





Fall "82" 


6 


Other "82" 


a 


Fall "81" 





Other 


5 


Unsure 


20 


Completely 


24 


Partially 


16 


Not at all 


5 


Very 


11 


Somewhat 


25 


Not at all 


6 


.Unsure 


1 


Yas 


16 


No 


29 


Location given 


14 


Unaure 


8 


Yes 


23 


Ho 


41 



31. What is the safest location? 



Igrim? Very 


27 


Somewhat 


23 


Not at all 


8 


Unaure 


5 


Not IfflDediate 


1 


Too early to tall 





Home 


15 


Basement 


9 


Under table/bed 





Public Shelter 


1 


Car 


2 


Other 


37 



9 


13 


3 




2 




1 














2 









2 




3 




3 


11 


6 














8 




1 









1 




8 


10 


1 









6 




8 





8 


6 


4 


10 


1 


3 


1 


2 





1 








2 


6 


6 


5 








1 


I 








5 


11 



223 



Taltphooa Sur»«y of 100 Kaddant* In tha Ei^rganey Planning Zonal Suwury of Uaulta 
Q^iaatlon ; 



32. 



If ordarad Co avaeuaca, whara vould you 
go? 

Hanover Mall 

Brldgavater St. Coll. 

Taunton Boap, 

Whcravar dlracCad 

To frlanda of family 

Juac away, no particular daatlnatlon 

Don't know 

Uould not avacuata 

Othar 



Plyoouth Klngaton Duxbury 

6* Kaapondanta 1 4 lUa. 22 Ka«. Tot«! 



t3. How would you gat thataT 



Own Car 

Other Car 

Public Traaaportatlon 

Other 

Uoaura 



34, Do you have a car available T 
(Weekdaya) 



(Weeknlghta) 



(Weakanda) 



- Yea 

No 

Soaatiaea 

Onaura 

Tea 

Ho 

SoaatlBca 

Unaure 

Yea 

No 
Soaatlaea 

Onaura 



35. 



Uhat If no car were avallablaT 



Call Spouac 

Neighbor 

Non-Neighbor 

Walk 

Public Tranaportation 

Contact Town Authority 

Would not evacuate 

Other 

Unaure 



6 

2 
1 
7 

IS 

15 

10 

6 



3 
1 

4 
4 



53 

» 
1 


55 

7 
1 


56 

7 





5 




1 

2 
3 
3 




12 
1 


1 



11 
2 
1 


II 
1 
2 


11 
1 
2 


2 
6 

1 
1 



1 

3 





3 


14 





. 2 





1 


7 


15 


5 


22 


3 


21 


2 


15 


1 


7 


1 


1 


18 


79 





4 





1 


4 


S 





5 



21 

1 


21 

1 


21 

1 



f3 

1 
3 
1 
3 
1 




83 

11 
3 


87 

t 
4 


88 

• 
} 


3 

50 
4 
6 
9 
1 
11 
10 
8 



224 



Que»tlon 



Tclcphon* Survey of 100 Kctldcnc* In Che Eaergency Flannlng Zone: Sumury of Rciult* 

bury 



36. If ordered Co take shelter what 
would you do? 



42. 



37. Do you have a basement 

(if not nentloned above)? 



Own basesienc 

Hose-not baseacnt 

Neighbor basement 

Public Shelter 

Evacuate 

Other 

Unsure 

Yes 
No 



38. Which provides greater protection: 

car or basement? 



Car 

Basement 
Unaure 



39. A cloud of radioactivity would be 
visible during the day. 



40. The exposure to radiation from 
an accident would be the aame as 
a chest x-ray. 



41. Boston Edison made a correct 
decision to cancel Pilgrla II. 



Agree 

Somewhat agree 

Disagree 

Somewhat disagree 

Unsure 

Agree 

Somewhat agree 

Somewhat disagree 

Unsure 

Disagree 



Agree 

Somewhat agree 

Somewhat disagree 

Disagree 

Unsure 

Refused 



rilgrlB officials have done everything 
possible for public awareness of 
emergency procedures. 



Agree 


15 


Somewhat agree 


18 


Somewhat disagree 


11 


Disagree 


13 


Unsura 


6 



43. Desth is possible within a few months 
of exposure to radiation during a 
major Pilgrim accident. 



Agree 

Somewhat agree 

Somewhat diaagree 

Dlaagree 

Unsure 



Plymouth Kingston Dux' 
64 Respondents 14 Res. M 



26 
12 

6 
5 
7 
8 

25 
13 

7 

45 
14 

3 
14 
23 
13 
13 


8 

10 
8 

39 

31 
4 
7 

18 
5 




16 
20 
10 
6 
10 



9 

3 
1 

1 

1 

4 
1 



12 

2 

3 

6 
3 
2 

2 


2 
10 

8 

3 
1 
2 




225 



T«l<Fhe«« Survajr e( 100 taaldmta la th* Eaargancy Flanaing Zona: Suaaary of lU 
QuMtlca 



Fljraouth Ungaton Dux 

6* Haapondanta U Itoa. 22 



alta 



lury 



laa. Tota] 



44. Veta ea quaaclon 3. 



Political ClaaalficatlonT 



4i. Marital StatuaT 



47. 



Imr rbyateally 41««bl*4 la 
)ieua«heldT 



4(, At* V^ 



4ff. mghMt Uval •( B4«c«tlen1 



Taa 


31 


No 


6 


Didn't Voca 


19 


Dnaura 


S 


lafuaad 


1 


Conaarvatlva 


20 


Modarata 


24 


Ubaral 


11 


Onaura 


10 


Slaila 


13 


Marrlad 


42 


Dlvorcad or Sapacated 


1 


Vldovad 


9 


tafuaad 





Taa 


3 


Rd 


St 


U - 24 


9 


25-34 


to 


35 - U 


14 


45 - 54 


5 


55 - «4 


9 


65* 


17 


Bafuaad 





Orada tehool 


3 


Se^ Ugh Mwol 


1 


lith School Ovad. 


24 


SoM Collogo 


17 


Collega Craduata 


11 


Voac Craduata Work 


4 


Hafuaad 






10 



51 

IS 

23 

S 

I 

34 

3a 

14 
IS 

22 
M 

3 
10 



« 

91 

» 
U 
25 

7 
12 
2« 

1 

3 

4 

35 

29 

17 

10 





226 



!\t;.kvii;i\1:R I'UONU numbur 

r)ATI: TOWN 



IMi.CRIM liMliRCHNCY PLANNING SURVLY 

"Hello, my name is . I'm calling from Opinions Unlimited, 

.1 ■ Massachusetts polling firm. We're doing a survey on emergency response 

in your arcn and we've selected your phone number at random, 
I'd like to get your opinion ou a tew things if I may? (IF YES, PROCUED) 

rirst of all, arc you a resident of 7" (IF YES, PROCEED) 

(same town as above) 

1. "What is your opinion of fire response capability in your area 
regarding response time to emergency calls? Would your rating 
be . . ." (RI-.AD CHOICLS) 

"Very C.ood" 1 

"Good" 2 

- "Fair" 3 

"of Poor" -4 

(Unsure) (DO NOT READ) 5 

2. "What is your opinion of the quality of the fire personnel and 
equipment in your area? Would your rating be . . ."(READ CHOICTS) 

"Very Good" — 1 

"Good" 2 . 

"Fair" 3 

"of Poor" 4 

(Unsure) (DO NOT READ) S 

3. "What is your opinion of ambulance response capability in your area 
regarding response time to emergency calls?. Would your rating 

be . . ." (RliAD CHOICES) 

"Very Good" 1 

"Good" 2 

"Fair" 3 

"Poor" --4 

(Unsure) (00 NOT READ) S 

Nkhat is your opinion of the quality of ambulance personnel and 
""Huipraent in your area? Would your rating be . T ." (READ CHOICES) 

"Very Good" 1 

"Good" 2 

"Piii r" - 3 

"Poor" -1 

(Unsure) (1>0 NOT READ) b 

"iio yovi ever work indoors nt an office or building other than your 
res idcnce?" 

Yes (INCI.UD!: SO.^IETIMES) \ 

•■^'o ^^;- SKIP TO Q. 3 

Unsure * 5/ 



10. 



227 



-2- 
'In what town is that office or building located?" 

TokTl ^ 

Same as residence -1 

Not same as residence, but job 



in Plymouth, Kingston or Duxbury --2 

All other towns ^ ^SKIP TO Q.8 

No job/ Unsure - 4J 



:> 



"When you are working indoors at that office or building other than 
your residence, can you hear police, fire or ambulance sirens if 
the windows and doors are closed?" 

Yes 1 

No 2 

Unsure - 3 

"Can you hear police, fire or ambulance sirens at your residence 
when your windows and doors are closed?" 

Yes 1 

No 2 

Unsure "5 



9 "Are you aware of any other public emergency warning systems?' (DO NOT 

READ) 
Pilgrim Nuclear Warning 1 CSKIP TO Q. H) 

All others 2 

No 3 

(ACTUAL RESPONSE IF "OTHER" 



(IF PILGRIM WARNING NOT MENTIONED, ASK): 

"Are you aware of a warning siren in case of an accident at the 

Pilgrim Nuclear Power Plant?" 

Yes 1 

No 2 



■ V (SKI 



CIP TO Q.ll ) 
Unsure -3 



228 



(II- AWARE OP PILGRIM SIRUN, ASK): 
11. "What does the Pilgrim siren mean?" (DO NOT READ) 

Accident 1 

Drill 2 

Other 3 

, Unsure- - 4 

(ACTUAL RESPONSE IF "OTHER"__ 



) 



12. "Have you ever heard the Pilgrim warning siren from your home or job? 

Home 1 

Job 2 

'^° ^ \— (SKIP TO Q. 16) 

Unsure ^^ 

(IF SIREN HAS BEEN HEARD AT EITHER HOME OR JOB, ASK): 

13. "Can you hear the Pilgrim warning siren well at (your home and/or 
your job (DEPENDING ON ANSWER TO Q. 6)] when the windows and doors are 
closed?" 

Home Job 

Well 1 Well 5 

Not well 2 Not well 6 

Not at all 3 Not at all 7 

Unsure 4 Unsure 8 

14. "Do you know the location of the siren nearest to your [home 

and/or job (AS APPROPRIATE)]?" 

Home Job 

Yes 1 Yes 4 

No 2 No 5 

Unsure 3 Unsure 6 

(IF YES FOR HOME OR JOB, ASK): 

15. "How far would you estimate the siren is from your [home and/or 
job (AS APPROPRIATE)]?" (READ FIRST THREE CHOICES) 

"Less than 1 mile"---i "Less than 1 mile" — 6 

"Between \ a mile "Between J a mile 

and one mile" 2 and one mile" 7 

"Over one mile" 3 "Over one mile" 8 

Unsure (DON'T READ)--4 Unsure (DON'T READ) --9 

Answer given, but Answer given, but 
interviewer doubts interviewer doubts 
credibility 5 credibility 10 



^ 



229 



- 4 - 

16. "What would be your first reaction if you heard the Pilgrim 
and a drill was not scheduled?" (DO NOT READ) 

Evacuate i-1 

Take shelter -.--2 

Turn on radio or TV --3 

Turn on radio or TV to an 
Emergency Broadcast Station--4 

Ignore- 5 

Unsure 6 

All other - 7 

(ACTUAL RESPONSE IF "OTHER" 



17. "Can you name one of the Emergency Broadcast Stations on radi 
in your area?" (CORRECT ANSWERS: WBZ-TV CHANNEL 4« WBZ 1030 
WATD 96 FM, WPLM 1390 AM/99.1 FM) 

Yes - 1 

No 2 

(IF THEY ASK FOR THE NAMES, GIVE THEM) 

18. "Have you ever heard a Pilgrim siren go off accidentally, 
when it wasn't supposed to? 



Yes 1 

'^° ^ ^ (SKIP TO Q. 20) 

Unsure 3 



> 



(IF YES) , 
19. "How many times have you heard a Pilgrim siren go off accident 

Once 1 

Twice - 2 

Over 2 ---3 (ACTUAL RESPONSE IF OVER 2: 



20. "If you heard the siren in the future, how would you determine 
whether it was a false alarm?" (DO NOT READ) 

Call someone 1 

Turn on Radio or TV 2 

Other 3 

Unsure --4 

(ACTUAL RESPONSE, IF "OTHER" 



230 



- s - 

21. "How much do you feel you know about emergency procedures in the 
case of a nuclear accident at Pilgrim? Do you feel you know a 
great deal; some, but not a great deal; very little; or nothing 
at all?" 

A great deal 1 

Some --2 

• • Not much, very little 3 

Nothing -- 4 

Unsure- 5 

22 "How 4id you learn what you do know about emergency procedures i 

in case of an accident at Pilgrim?" (DO NOT READ) j 

TV, radio, newspaper- -1 

Official Emergency Planning Brochure 2 

Word of mouth 3 

Other - -- 4 

(ACTUAL RESPONSE IF "OTHER" 

) 

23. "Have you ever received an Emergency Public Information Brochure 
in the mail?" 

Yes 1 

^° ■ ^ \^ (SKIP TO Q."29) 

Unsure ^ ^y 

(IF "YES", ASK) : 

24. "When did you receive it? Do you remember what month?" 

Sept. '82 1 Fall '81 S 

Oct. '82 2 Other '81 6 

Fall '82 3 Other- 7 

.Other '82 4 Unsure 8 

(RESPONSE FOR "OTHER" ) 

25. "Would you say you read (PRONOUNCE "red") the brochure..." (REAP RESPONSES 

"Completely", 1 

"Partially", - 2 

"or. Not at all". 3 (SKIP TO Q. 27 FOR #3 ONLY) 

26. "Did you find it very helpful, somewhat helpful, or not at all 
helpful?" 

Very 1 

Somewhat 2 

Not at all 3 

■ Unsure 4 

27. "Do you have your emergency brochure available right now?" 

Yes 1 

No 2 iSKIP TO Q. 29) 



231 



- c - 
(11- Yi-:s), 

28. "Where do you keep it?" (DON'T PRESS FOR AN ANSWER] 

If location given --1 

Unsure of location 2 

ASK EVERYONE 

29. ''Do you have any questions regarding emergency planning in the 

case of a nuclear accident at Pilgrim 17^' (IF YES: "What 
questions?^ 



30. 



Let's imagine for a moment that the warning siren has indicated 
that there had been a nuclear accident at Pilgrim I. 

"As far as you know, how dangerous is the situation? Would you 
consider the situation to be . . ." (READ CHOICES) 

"Very dangerous",- -------1 

"Somewhat dangerous", 2 

or "Not at all dangerous",- - - - - 3 

Unsure - 4| 

No immediate danger 5 V (DO NOT READ) 

Too early to tell ------- 6_J 

31 "Where do you believe is the safest location for you during 

this situation?" (if siren indicates an accident at Pilgrim)(DO NOT READ) 

Home --------1 

Basement ------------2 

Under table or bed -3 

Public shelter ---------4 

Car 5 

Other - - - 6 

(ACTUAL RESPONSE IF "OTHER" 

) 



32. ''If you were ordered to evacuate because of an accident at 
Pilgrim where would you go?" (DO NOT READ) 

Hanover Mall -----i 

Bridgewater State College - - - 2 

Taunton State Hospital ----- 3 

Wherever directed- --4 

Other --- -..-5 

(ACTUAL RESPONSE LF "OTHER" 

) 



34 



36. 



232 



.33. "How would you get there?" (DO NOT READ) 

Personal car -----------------1 

Other car (neighbor, relative, friend) - - - -I 

Public transportation -- 3 

Other- - - " 

> Unsure ---------- ---S 



(ACTUAL RESPONSE IF "OTHER" 



) 



"Do you have a car available for your use?" 

" Weekdays " " Weeknights " "and Weekends " 

Yes 1 Yes 5 Yes 9 

No 2 No 6 No 10 

Sometimes - - 3 Sometimes - - 7 Sometimes - - 11 

Unsure- - - - 4 Unsure- - - - 8 Unsure - - - 12 

35 "What would you do if you were ordered to evacuate and you 
had no car available?" (DO NOT READ) 

Phone spouse 1 

Contact neighbor for a ride - - - - 2 

Phone non-neighbor for a ride - - - 3 

Walk away ^ 

Walk to public "staging area" 

for public transportation - - - - 5 

Take shelter - - - . - - 6 

Other 7 

Unsure ------ 

(ACTUAL RESPONSE IF "OTHER" 



8 



) 



"If you were ordered to take shelter because of an accident at 
Pilgrim I, where would you go?" (DO NOT READ") 

Own basement ------------1 

Home - other than basement ----- 2 

Neighbor's basement 3 

Public shelter - * 



Evacuate 



5 



Other - - 6 



Unsure ----- 

(ACTUAL RESPONSE IF "OTHER" 



7 



233 



.37. IF "OWN BASEMENT"or "CELLAR", NOT MENTIONED, ASK: 
"Does your home have a basement?" 
Yes ------ 1 

No 2 

38. "Which would provide greater protection from radiation?" 

"your car", - -1 

"or your basement", - - - - 2 

unsure 3 (DON'T READ) 

"I'd like to read you five statements. Please tell me if you completely 
agree, somewhat agree, somewhat disagree or completely disagree with 
each statement." 

39. "If a cloud of radioactivity were released during an accident at 
Pilgrim, it would be visible during the day." 

Completely agree 1 

Somewhat agree - - - -2 

Somewhat disagree -- 3 

Completely disagree ------ -4 

Unsure 5 

40. "The exposure to a person outdoors from the radiation released 
during a major accident at Pilgrim would be about the same as 
the exposure from a chest X-ray." 

Completely agree 1 

Somewhat agree -----2 

Somewhat disagree --------5 

Completely disagree 4 

Unsure -----S 

41. "Boston Edison made the correct decision when they cancelled plans 
to build Pilgrim II, a second nuclear powered generating plant." 

Completely agree 1 

Somewhat agree 2 

Somewhat disagree --------3 

Completely disagree 4 

Unsure 5 



234 



42 "The emergency officials at Pilgrim I have done everything 
they could to insure maximum public awareness of emergency 
procedures . " 

Completely agree ----- 1 

Somewhat agree 2 

Somewhat disagree 3 

Completely disagree - 4 

Unsure -- --------5 

43 "The exposure to a person outdoors from the radiation released 
during a major accident at Pilgrim could cause death within 

a few months." 

Completely agree -.---1 

Somewhat agree ----- 2 

Somewhat disagree --- 3 

Completely disagree 4 

Unsure ----- -...--5 

44. "Did you vote "Yes" or "No" on Question 3 on the November 

ballot? Question 3 proposed a law that would require that all 
construction or operation of new nuclear power plants or 
radioactive waste disposal facilities be subject to voter 
approval in statewide elections." 

Yes 1 

No - - 2 

Didn't vote - - • • - 3 
Unsure -------4 

Refused - - 5 



235 



- U) - 

"linally, i iu>l h.i\'c ,i feu questions foi c 1 .1 ss i f i i:;i t i on injiposcs. 

45. 'Vol I t iciil ly , -li) you consitlci yourself to be i\..." (RliAD CHOICES] 
■ ■ "Conservative", 1 

"Modciate" ,-- Z 

"or , I. ibe ral" !^ 

. (DO N'O; RI^.AIl) Unsuie- -4 

46. "Wliat is your marital status?" (lUiAP CHOlCliS) 

"Single", 1 

"Married" , 2 

"Divorced or separated", 3 

"or. Widowed". --4 

Refused 5 

"How many people including yourself, live in your home?" 
(RldCORD NUMBER ) 

47. "Are there any physically disabled persons living in your household?" 

Yes--- 1 

No 2 

48. "In which of the following groups is your age?" (READ CHOICES) 

" 18-24- 1 

*2S-34" 2 

••35.44-. 3 

'45-54'- 4 

■"5 5-64" 5 

"65 and over 6 

Refused-- 7 

49. "What is the highest level of education you have achieved?" (READ CHOICES) 

"High school graduate - 1 

' Some college 2 

College graduate 3 

"Post-graduate work or degree 4 

Refused 5 

"Thank you very much for your assistance. Good-bye." 

50. (RECORD SEX) FEMALE--- --1 MALE 2 



236 



C W 

m *• 

V 

s. t 



tV. 



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55- 

gS = 

■ ti 41 



w « ^ 

CO. -o 

■ — w « 

U It H 

• «- U 

r -^ -^ m 

w k. C w 

>- a-Q 



» 3 X 

U •' 

« C -3 

•rf V « 

C w J£ 

a X u 

u « a 

o • t; 

aC £ « 



■ G 



lei 



£ - 



s s :: 



(ACM 



3 w w 



, t 



1^ >t 

o a 



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NO EXIT 




The MASSPIRG Survey of 
Pilgrim Evacuation Planning 



MASSPIRG 
September 1987 



244 



NO EXIT 



THE MASSPIRG SURVEY OF PILGRIM EVACUATION PLANNING 



Authors 

Josh Kratka 
Rachel Shimshak 



Research and Technical Experts 

David Nemtzow 
Alan Nogee 



Survey Director 
Maria Mobil ia 



MASSPIRG 

29 Temple Place 

Boston. MA 02111 

(617)292-4800 

September 1987 



245 



ACKNOWLEDGMENT 

Special thanks are owed to David Nemtzow of the Kennedy School of 
Government who supervised the survey and conducted the statistical analysis, 
to Maria Mobilia for coordinating the survey callers, and to the many MASSPIRG 
researchers who spent hours on the phone compiling the necessary data for this 
report. Thanks also to Amy Kelley for the cover design. Sue Haynie for 
production of this report, and Mike Ernst of the State Legislature's Energy 
Committee for reviewing an earlier draft of this document. 



246 



TABLE OF CONTENTS 

EXECUTIVE SUMMARY 1 

I. INTRODUCTION: THE LESSONS OF CHERNOBYL 3 

II. SURVEY RESULTS: PILGRIM DISASTER PLANS ARE STILL A DISASTER 

A. Pilgrim-Area Residents Are Inadequately Informed 

About Emergency Planning 7 

B. Residents Will Not Follow the Emergency Plans 10 

C. The Emergency Plans Do Not Address the Needs of 

Many Population Groups 

1. Families With Children 12 

2. The Elderly 13 

3. Newer Residents 14 

D. The Flaws Revealed by the Survey Render the Emergency 

Plans Unworkable 

1. Present Warning Methods Are Unlikely to Alert 

Res ident s Quickly 15 

2. Phone Lines Are Likely To Be Tied Up During an 

Erne r gency 15 

3. Orderly Evacuation is Unlikely to Occur 16 

E. Most Residents Surveyed Want Pilgrim to Remain Shut Down ..18 

III. DETAILED SUMMARY OF QUESTIONS AND RESPONSES 

A. Methodology 19 

B. The Survey 20 

IV. RECOMMENDATIONS 33 



247 



EXECUTIVE SUMMARY 

In light of the General Accounting Office's finding that no federal agency 
assesses public knowledge of radiological emergency procedures. MASSPIRG 
surveyed 363 residents of the Pilgrim nuclear power plant's Emergency Planning 
Zone (EPZ) to determine what people know about the official emergency plans and 
whether they would follow those plans in case of an accident at Pilgrim. 

The key findings of this survey show that residents are even less 
informed about Pilgrim emergency plans than they were at the time of 
MASSPIRG's last such survey, conducted in 1983. Moreover, they would refuse to 
follow official instructions in the event of an emergency. 

1. Residents have only a limited knowledge of emergency plans for their 
communities . Only 56% of those surveyed said they had received the Emergency 
Public Information booklet from Boston Edison, the operator of the plant, 
compared with 67% who remembered receiving the booklet in 1983. Moreover, only 
23% of those surveyed said they had actually read the booklet completely, 
compared to 38% in 1983. Those living in the EPZ for three years or less have 
been particularly ill-informed: 47% had not received a copy of the booklet. 

2. Many residents would not follow the emergency plans in case of a 
serious problem at Pilgrim ; 

* the most common response to an accident at Pilgrim (27% of those 
polled) would be immediate evacuation — a direct contradiction of instructions 
contained in the emergency information booklet: 

* only 19% of those questioned said they would go to one of the 
designated reception centers in case of an evacuation, and two-thirds of these 
few who would follow the emergency plans would go to the Hanover Mall, which is 
no longer an official reception center; 



248 



* of the 37% surveyed who have school-age children, nearly half (48%) 
said that they would try to pick up their children from school in the event of 
an emergency — precisely what the emergency booklet instructs them not to do; 
just 9% of parents said they would follow the instructions to meet their 
children outside the danger zone. 

3. The emergency plans do not adequately take into account the special 
needs of children and the elderly . 

4. Seventy-nine percent of the respondents felt that Pilgrim should 
remain shut down if management and safety problems persist . 

5. When asked whom they would trust for information in the event of an 
accident. 3H of respondents said they would have no confidence in Boston 
Ediaon. easily the worst score aiiong the people and groups mentioned . 

Since the accident at Three Mile Island, the Nuclear Regulatory Connission 
has required ccoaunities within a 10-nile radius of a plant to have workable 
evacuation plans. In July 1987, the Federal Emergency Management Agency 
(FEMA) found the Pilgrim plans inadequate to protect public health and safety 
and withdrew its interim approval of them. The findings in HASSPIRG'a report 
clearly show that, given the current level of information, the Pilgrim 
emergency plans would not adequately protect the public even if the 
deficiencies identified by FEMA were corrected. 

In light of these results and aerious management and safety problems at 
Pilgrim, MASSPIR6 recommends that the Pilgrim plant should not reopen unless it 
is determined that: 

(1) workable plans can be developed; 

(2) such plans have been effectively disseminated and implemented, and 

(3) outstanding management, safety, and economic questions have been 
resolved. 



249 



I. INTRODUCTION: THE LESSONS OF CHER>10BYL 
7 'e Chemobj'l disaster it April of 1986 provided a sobering glimpse of 
' ' ''^. Lu -:.le devastation that could result from a nuclear power plant 
■ ■ -idci'- The Soviet government was forced to evacuate 135,000 people living 
Jichln an 18.6-mile radius around i-he plant. Thirty-one people have already 
aieu a^ a direct result of the accident, and 24,000 more are expected to die of 
a.-<=r ca"sed by rac'iation exposure. Fallout from the plant contaminated crops 
. .;C dairy products across Eastern Europe and vas detected as far away as the 
vt.ct coa-.t of the United States. On June 16, 1987, the Boston Globe quoted 
:,(.:istantin Fursov, a So^ritit olf ioi.-.^ , to the tite<-L that 27 cities and villages 
within an 13-mile radius of the plant are "too contaminated for people to live 
in for the foreseeable future." The world learned — the hard way — that 
i-oi'-'erts can and will happen, with devastating consequences. 

The Chernobyl accident halped fuel the debate in the United States about 
n -li.ar pcwer in genaral, and in Massachusetts over safety and evacuation 
' L.OE at the troubled Pilgrim nuclear power plant. 

'licensed in 1972, the Pilgrim reactor in Plymouth, Massachusetts, has led 
-; -crturtd life. Initially, the plant was loaded with "bad" fuel which 
substantially increased the radioactivity in the plant. As a result of this 
• J other problems. Pilgrim has only produced about half as much energy as it 
•.o'lld if it had been working continuously at full power over its life today. 
In 1982, Boston Edison, the owner and operator of the Pilgrim plant, 
reived the largest fine levied against a power plant at th?t time, for two 

•sty violations and a "material false statement." The Nuclear Regulatory 
commission (NRC) was so ccncemed abo-it conditions at Pilgrim that it ordered 
■:..' y^iiir.y to conduct a "management overhaul" in that same year. 



250 



Despite promises to improve its operations in 1982, the plant continued 
to receive poor grades from the NRC in its periodic management performance 
reports. 

RBCENT BISTORT 

In early April of 1986, the reactor experienced two "unexplainable 
automatic shutdowns" or "scrams," touching off 17 months of harsh criticism 
from the NRC, elected officials and citizen groups across the state about 
Pilgrim's problems. Ir a May 1986 Congressional hearing, the NRC labeled 
Pilgrim one of the "worst managed and least saie plants in the country." The 
morning papers began to carry headlines such as "Pilgrim Missed Another 
Deadline for Safety Tests. "Pilgrim Workers' Radiation Exposure Among Nation's 
Highest," and "New Doubts Voiced on Future of Pilgrim." 

The Department of Public Utilities issued a scathing indictment of Boston 
Edison in June of that year accusing the company's management of being 
"paralysed" to the point where officials are no longer able to properly run the 
plant. The 300-page report stated that if Edison continued along its current 
path, "it will jeopardize the health and safety of its customers and the 
economy of the region." 

After documenting years of management, structural, and evacuation problems 
at the plant, MASSPIRG submitted a 50-page petition to the NRC asking the 
Commission to suspend Pilgrim's license until all of the safety issues were 
resolved, and to hold a comprehensive public hearing to discuss each problem. 
Joining MASSPIRG in filing the "Show Cause" petition were over 50 state 
legislators, a dozen citizen groups, and statewide candidates for attorney 
general and lieutenant governor. The theme of the petition was that taken 
individually, the problems described are serious. In the aggregate, they 
thoroughly compromise the reliability of the most important safety systems 



251 



*:hp plant .md destroy the fundamental principle of defense-in-depth 
•^por,r,e<i by the NRC. 

Some of the emergency planning deficiencies noted in the petition were: 

1} Lack of advance information about emergencies for residents, 

'-anintnts, and tourists; 

2) Lack oi adequate medical facilities to treat contaminated individuals 
i.n the event of an emergency; 

3) Lack of emergency plans for Cape Cod, located 11 miles from the 
P-lgriiB plant, and other communities just outside the official evacuation 
;■ 'anning zone; 

4) A lack of attention tc .smergency planning by federal, state and local 
'jovernment agencies; 

5) Lack oI adequate capability and planning for notification during an 
accident, and 

6) Lack of adequate plan^ for evacuating the physically disabled, nursing 
home residents, school children, hospital patients, campers, and inmates of 
correctional facilities. 

Secretary of Public Safety Charles Barry underscored the problem areas 

roted in the petition in a 100-pagc report to the Federal Emergency Management 

Agency (FEMA) in December of 198d. At a December State House hearing. 

Governor Dukakis submitted that report and stated that Pilgrim should remain 

closed until ai' 1 previously identified management, reactor safety and 

emergency planning concerns have been adequately addressed. 

In light of this criticism, Edison should have been well on its way toward 

cleaning up its management and safety problems by 1987. But the most recent 

:'''.C pe-=crmance repor" Clo. 50-293/86-99. dated April 8, 1987) concludes that 

tnere are "significant recurring program weaknesses ... and that the rate of 

change was slow during most of the assessment period." In five of the twelve 

functional areas graded by the NRC, Pilgrim received the lowest possible score. 

Thes^- developTients and other;: led a special legislative conunittee on Pilgrim to 

issue yet another report critical of the plant and its operations in July 1987. 



252 



E7ACDATI0N nj^NNING TODAY 

After the accident at Three Mile Island in 1979, the NRC required nuclear 
plants to have workable emergency evacuation plans for the population living 
within a 10-mile radius around the plant. In the case of the Pilgrim plant, 
Boston Edison's record of safety violations and management problems makes the 
existence of feasible evacuation plans that much more critical. 

After 17 months of shutdown, however, there is still no progress on the 
workability of emergency plans for the Pilgrim area. On August 6, 1987, FEMA 
released a report, entitled "Self-Initiated Review and Interim Finding," which 
further criticized Pilgrim's emergency plans and found them "inadequate to 
protect the health and safety of the public in the event of an accident," The 
five reasons highlighted in the FEMA finding were: 

* Lack of evacuation plans for public and private schools and day-care 
centers; 

* Lack of a reception center for people evacuating to the north: 

* Lack of identifiable public shelters for the beach population; 

* Inadequate planning for the evacuation of the special needs and 
transport dependent population; 

* Overall lack of progress in planning and apparent diminution in 
emergency preparedness. 

Many of the inadequacies cited in the FEMA report had been raised years 
before by MASSPIRG in its 1977 and 1983 reports on evacuation planning, 
entitled "blueprint for Chaos" I & II, and most recently in the July 1986 "Show 
Cause" petition. Because several conditions which affect emergency planning 
have worsened in the past few years, MASSPIRG decided to follow up its earlier 
reports with this study. 

The 1977 and '83 reports generally looked at the adequacy of emergency 
plans themselves, as did the recent FEMA study. This report approaches the 



253 



5=mergC;ncy plan; rrott a diilcrexii; o I'^ie ■- it ijoks mc it the plans themselves 
but at the people who w3.ll be ask?d tc follou t'n.;rr.. Such information is 
crucial to assessing the feasibility of the plans, particularly in light of the 
General Accounting Office's finding that "no federal agency assesses public 
knowledge of radiological emergency procedures." (GAO Report to Hon. Edward 
J. Markey, House of Representativc^i, "Nuclear Regulation: Public Knowledge of 
Radiological Emergency Procedures," June 1987, p. 1.) 

MASSPIRG surveyed 363 people vho live in the Pilgrisn Emergency Planning 
Zone (EPZ) to answer these basic quest-.onti; 

(1) Are EPZ residents kntiwiedgeaL'^e ;ibout the emergency plans? 

(2) Will residents be wii Ling and able to follow tiiese plans? 

(3) What do residents think about emergency planning and the Pilgrim 
nuclear plant in general? 

The survey methodology, along with the orecise questions and answers are 

described in Section III. 

I I . SURVEY RESULTS: PILGRIM DISASTER FLANS ARE STILL A DISASTER 

A. PILGRIM-AREA RESIDENTS ARE INADEQUATELY INFORMED ABOUT EMERGENCY PLANNING 
The first major conclusion to be drawn f'-om out survey is that the 
residents of Plymouth, Kingston, Duxbury and Carver have, on the whole, a very 
limited knowledge of the emergency plans for their communities, and that they 
are even less well informed now than they were four years ago. This conclusion 
is apparent from the responses to virtually every survev question which tested 
familiarity with the basics of the emergency plans, from warning methods to 
evacuation procedures. 

A large share of the blame for this situation must be attributed to Boston 
E'iison's failure to educate the public. The company has relied almost solely 
on its booklet, "Emergency Public Information: What To Do In Case of an 



254 



Emergency at Pilgrim Nuclear Power Station," and claims to have distributed 
copies of it to all residents ot the EPZ in November 1986. There have 
obviously been distribution problems: just over half (56%) of those surveyed 
said they had received the booklet (see Question 9). This figure represents a 
noticeable step backwards from 1983. the last time MASSPIRG surveyed EPZ 
residents. In 1983, 67% of those surveyed said they had received a copy of the 
emergency planning booklet. 

An added problem with relying heavily on written information is that not 
everyone who gets it reads it. Nearly two-thirds (62%) of those who received 
the booklet admitted to us that they had read it only partially or had not read 
it at all (see Table 1. below). Thus, while 56% of the total sample remembered 
receiving the emergency information booklet (Q. 9), a mere 23% had .read it all 
the way through. In 1983, 38% of those surveyed by MASSPIRG said they had read 
the booklet completely. The lack of public education suggested by these 
numbers is verified by the answers to several other questions. 

TABLE 1 

SURVEY RESPONDENTS WHO HAD READ THE EMERGENCY PLANNING BOOKLET ... 

% of Those Who % of Total 
Number Received Booklet Responses 

COMPLETELY 82 33 23 

PARTIALLY 109 4 A 30 

NOT AT ALL/NEVER 149 18 41 

RECEIVED BOOKLET 

DON'T KNOW/REFUSED 23 5 6 

(Based on responses to Questions 9 and 10) 

While most respondents knew that warning sirens would be used to signal an 
accident at Pilgrim, very few knew that they should also tune in to local 



255 



television and radio stations to receive more complete information and 
instructions on what to do (Q. 2. 12). This becomes more significant in light 
of the fact that the respondents' most common reaction to learning of an 
accident at Pilgrim would be to evacuate immediately, contradicting the express 
directions in the emergency information booklet (Q. 11). There is a great 
danger, therefore, that people will hear the siren and flee without waiting to 
receive important information and instructions. 

Even when evacuation is the right action to take, few of those we surveyed 
would know where to go. Less than one in five named one of the three 
evacuation centers specified in the booklet, and of those few who knew where to 
go. a third did not know the proper route to tfke (Q. 14, 15). The problem is 
even more acute for parents of school-age children. Nearly 70% of the parents 
surveyed would not know where to find their children if an evacuation 
occurred during school hours. The evacuation plans call for school children to 
be bused to special reception centers directly from school, but the emergency 
booklet does not list the locations of those centers. 

We also found that the Carver residents we surveyed exhibited a noticeably 
lower degree of familiarity with emergency procedures than residents of the 
other three towns within the EPZ. Thirty-six percent of Carver residents, for 
example, said they had never heard the Pilgrim warning siren (compared to 13% 
for residents of Plymouth) (Q. 3). Not surprisingly, then. Carver residents 
were the least likely to be able to distinguish the Pilgrim warning from other 
warning sirens (Q. 7). 

The survey as a whole reveslfid a genera'' Icck of information on the part 
of the public. But Carver residents also displayed a surprising amount of 
mis information about the evacuation plans. Two-thirds of those who said they 
would go to one of the evacuation centers in case of an accident named the 
wrong center for their area (Q. 14). 



256 



It is clear that Boston Edison needs to make additional efforts to include 
Carver in warning drills and to counter misinformation about the evacuation 
plans. 

The confusion and panic that could spread from large numbers of people not 
knowing what to do in a pressure-filled situation might be impossible to quell. 
But ignorance of the Pilgrim emergency plans is far from the only problem we 
found. 

B. RESIDENTS WILL NOT FOLLOV THE EMERGENCY PLANS 
Several survey responses suggeot dtront^j.) that many people in the EPZ 
would not follow the procedures outlined in the emergency planning booklet 
even if they were familiar with them. This finding represents perhaps the 
most serious challenge to the workability of the Pilgrim emergency plans. 

Many recurrent, unsolicited comments made by survey respondents 
demonstrated a pervasive belief that the emergency plans do not represent a 
sensible response to a serious accident at Pilgrim. In case of a serious 
accident, the first thing many respondents would do is "pray" or "Iciss my wife" 
or "panic." Evacuees would head not to one of the emergency reception centers 
but "whichever way the wind isn't blowing." How will the authorities warn 
people in case of an accident? A surprising number answered, "What difference 
does it make?" 

The conclusion that EPZ residents would not follow the emergency plans is 
not based merely on these off-the-cuff remarks. Many of the "hard numbers" 
point in the same direction. Just 19% of those polled, for example, said they 
would follow the evacuation plan outlined in the emergency information booklet 
(Q. lA) . While a large part of the reason for this low number could simply be 
ignorance of the plans (see previous section), only 2% of those answering the 
same question said that they would go wherever directed, indicating little 

10 



257 



willingness to wait for evacuation planners to provide any advice (Q. 14). 

The survey also showed thitt most residents who have children m school in 
the area will not follow the existing evacuation plans in the event of an 
accident at Pilgrim. If such a situation were to arise, just 3% of parents 
said they would wait for their children to come home from school and only 9X 
would attempt to meet them outside the danger zone, as the emergency booklet 
advises. Forty-eight percent said they would trv to pick their children up 
from school — precisely the thing they are not supposed to do. Another 37% 
did not know what they would do or gave another answer (Q. 18). 

Again, only a part of this response is due to ignorance. Ever, when 

specifically informed of the proper procedures to follow in case a family 

member were in school or a hospital during an evacuation, barely over half 

(51%) of the respondents thought they "would be able" to follow instructions 

directing them not to try to pick up their family members themselves. Those 

who gave a reason for for disobeying the instructions typically explained that 

they simply could not entrust the safety of a family member to the authorities, 

that this was their responsibility (Q. 22). 

TABLE 2 

WHAT PARENTS OF SCHOOL -AGE CHILDREN WOULD DC IN CASE OF AN ACCIDENT AT PILGRIM 

DURING SCHOOL HOURS 

% of Parents With 
Number Children in Area Schools 

Get children from school 65 48 

Wait for them to come home 4 3 

*Meet them outside danger zone 13 9 

Other 27 20 

Don't know 22 17 

* Correct answer, according to emergency planning booklet. 

(Based on responses to Question 18) 

11 



258 



C. THE EMERGENCY PLANS DO NOT ADDRESS THE NEEDS OF MANY POPITLATION GROUPS 
As the Federal Emergency Management Agency has finally acknowledged, lack 
of education and widespread distrust are not the only problems with the 
Pilgrim emergency plans. Our survey revealed that the plans fail to 
adequately address the needs of families with children, the elderly, and those 
who have lived in the area for three years or less. 

1. FAMILIES WITH CHILDREN 
Whether because of the lack of an aggressive public education program or 
simply because of a poorly designed plan, an ai-tempt to evacuate families with 
school-age children according to the existing plans will almost surely meet 
with failure. This constitutes perhaps the most serious flaw in the emergency 
plans. 

More than a third (3 7%) of the people surveyed have children under 16 who 
go to school in the Pilgrim area (Q. 16). Few of them would be either willing 
or able to follow the evacuation procedures outlined in the emergency plans if 
an accident were to occur during school hours. As noted in section B and Table 
2 above, virtually half of parents surveyed (48%) would actually do whet the 
emergency planning booklet tells them not to do — pick up their children from 
school themselves. 

The evacuation plans are premised on a smooth flow of traffic in a 
specific direction along the designated routes. A significant portion of the 
population trying to get to schools all over the EPZ would seriously disrupt 
planned traffic patterns. Though the evacuation plans call for school children 
to be transported directly to special evacuation centers, seven out of ten 
parents we spoke to would not know where to find their children if that 
happened (Q. 19). 

A different set of problems would arise if an accident occurred after 

12 



259 



school hours but while many prirents were still at work. More than a third of 
the parents we polled tcl^ us that their children are sometimes left unattended 
after school lets out (0. 17). .\ccording to the emergency booklet, parents 
away from their homef "may not. be pf='rmitteQ to return [to the affected areas] 
during the evacuation,'' leavirg unknown numbers of children to fend for 
themselves. 

2, rue ELDER I.Y 

Many of the problems we found with the Pilgrim emergency plans are simply 

exacerbated when dealing with those 65 and older. This group of survey 

respondents had even le&s familiarity with the plans than did the general 

population. More than a fourth did not know that there is an emergency 

evacuation plan in case of an nceident at Pilgrim; few knew that warnings 

and information would be sent out over local television and radio (Q. 1, 2, 

12). And even if they were to hear a warning siren, a third doubted whether 

they would know what the warning was for (Q. 7). 

TPSl.^ 3 

FAMILIARITY WITH EMHPGENCY PROCEDURES: RESPONDENTS AGE 65 AND OVER 
COMPARED WITH GENERAL POPULATION 

% of Total % of Respondents 
Responses Age 65 and Over 

Aware that emergency plans exist for 

your town? Ye.=! 87 7A 

26 

How will people be warned of Pilgrin 

accident? Siren 75 64 

6 
14 
Gould distinguish Pilgrim siren iru_. 

other sirens? Yes 5 9 45 



Know how to get instructions in cir,£ 
of emergency? 



Ye.=! 


87 


No 


13 


Siren 


75 


r//Radio 


19 


Don't Know 


10 


Yes 


59 


No 


21 


TV/Padic 


33 


Other 


9 


No 


57 



29 

19 

6 

72 



(Based on response;^ to Questions 1, 2, 7 and 12) 



13 



260 



The elderly also face one problem that most others (aside from children) 
in the EPZ do not: lack of acc<?s6 to an automobile. At any given time, as 
many as 12% of these over 65 would not have a car available for their use, 
compared with two or three percent in the general population (Q. 20). Locating 
and transporting these people may present a difficult problem for evacuation 
planners. 

3. NEWER RESIDENTS 
Those who have lived in the Emergency Planning Zone for three years or 
less are, in general, the least well informed about emergency planning and 
about the Pilgrim plant in general. Forty-seven percent of these newer 
residents, who make up nearly a quarter of all those we surveyed, had not 
received a copy of the emergency planning booklet (Q. 9). Moreover, only half 
of them have ever heard the Pilgrim warning siren, compared with more than 80% 
of the rest of those we surveyed (Q. 3). All the problems associated with 
ignorance of the emergency procedures discussed above thus apply with even 
greater force to this large demographic group. 

It is unlikely that this problem is the result of apathy on the part of 
those new to the area. Among new residents who initially thought that the 
Pilgrim plant should be reopened (Q. 25), more than three-fourths (77%) 
changed their opinion when informed that the NRC had found serious safety and 
management problems at the plant, compared to a 54% turnaround among the total 
sample (Q. 26). This was the largest turnaround we found, strongly suggesting 
that it is simply lack of information which distinguishes these residents from 
others. Boston Edison's failure to reach any more than half of these 
residents with emergency information or warning drills thus could be a primary 
cause of their inability to cope effectively with an emergency situation. 



14 



261 



J. niE Bl.AWS REVHALEi: 3Y T!'E L^URVSY RENDER THE F.^;ERGHNC•y PLANS UNWORKABLE 
The probleas ou'.J med in the ;;reced.irg rhree sections reveal significant 
defects in both the design and iiipi'tnentat ion of emergency plans for the 
Pilgrim area. Much of the affected population is unfairiiliar with basic 
elements of the plana, many who are familiar with the plans will not follow 
them, ana the needs cf identifiable groups of people have simply not been 
addressed either in the plans' design or in the dissemination of emergency 
information. 

Our survey uncovered a number of other problems which, combined with those 
mentioned above, will make an GVijCUj.:ion uiiwoikaiilt . 

1 . P RESENT VJARNING METHO DS ARE UNLIK ELY TO ALERT RESIDENTS QUICKLY 
It seems apparent from out findings that a significant number of residents 
might not receive effective warring and accurate information quickly enough to 
be of any use during the short time in which a serious accident could develop. 

Use of the v;arriing sirens alone is not enough. Over 40% of those we 
surveyed said that they could not hear the sirens well or at all when their 
doors and windows were closed (Q. 4). In addition, many of those who are 
familiar with the sirens have heard them sl' often ("everv time there is an 
electrical storm") that simply heading a siren would not immediately alert 
them to an actual accident in progress (Q. 3, 6). 

2. PHONE LINES ARE LIKF.LY TO BE TIED UP DURING AN EMERGENCY 
Only a third of our survev sample knew that emergency information would be 
available on local television and radio (Q. 12';. It is not surprising, then, 
that nearly two-thirds of the pe'^nle we polled rsid that thev would use the 
telephone to find out emergencv information or to find cut information about 
family members (Q. 13). This ie particularly i:nderstandable in light of the 
fact that the emergency information booklet contains no instructions against 



15 



262 



y;;-'.ng the Telephone during en eiotTgency. 

Thousands of peoplp all picking up the phone at nearly the same time is 
sure to tie up phone lines and make communication virtually impossible, further 
hindering an effective response to a serious accident at Pilgrim. 

3. ORDERLY EVACUATION IS UNLIKELY TO OCCUR 
The obstacles facing those trying to devise a way of evacuating all the 
residents of the EPZ in case of a serious accident at Pilgrim may well be 
insurmountable under the best conditions. The problems already discussed 
above make it abundantly clear that those planning for evacuation now are 
operating in a situation that is far from ideal. 

The lack of familiarity with the existing plans and the lack of confidence 
that those plans will work are the most obvious problems. Although, directed to 
stay inside and wait for instructions by the emergency information booklet, the 
initial response to an accident situation among many of those we surveyed 
included evacuation (27%), making phone calls, packing, and gathering the 
family (9%, 2%, and 12%, respectively), and a variety of responses subsumed 
under the categories of "don't know" and "other" (12% and 18%, respectively) 
(Q. 11). Those who would evacuate, even if properly directed to do so, would 
flee in all possible directions — "whichever way the wind isn't blowing," in 
the words of one respondent — forsaking the planned escape routes mapped out 
in the booklet (Q. lA, 15). For many that is not an irrational decision: 
Hanover Mall, one of the evacuation centers listed in the current emergency 
information booklet, has withdrawn as an evacuation center! 

An intensive program of public education could perhaps overcome some of 
the flaws identified in the survey. It is uncertain, however, whether 
education would be enough to convince parents of young children, or people with 
family members in a hospital or nursing home, to leave their family members to 



16 



263 



th'-' autboritie'j Cor e\'acuation. The plan simply does not take into account the 
strong impulse, particularly of parents, to see to the safety of their children 
themselves (Q. 18, 22). 

Finally, the evacuation plan depends primarily on most residents' ability 
tc get themselves out of the danger zone, with emergency workers left to see to 
any others. Our survey showed that approximately 95% of the people in the EPZ 
have access to a car at any given time (Q. 20). The effect of nearly every 
automobile in the towns of Plymouth, Carver, Kingston and Duxbury taking to the 
reads at the same time is unprecedented and almost unimaginable. Add to that 
number the residents of the area surrounding the Pilgrim EPZ. During the Three 
Mile Island emergency, for example, when authorities ordered 2,500 women and 
young children to evacuate 14A,000 people took to the roads. 

One respondent commented that it is virtually impoesible to get through 
traffic when there is a snowstorm and a few cars break down; he could not 
conceive of the problems that would ensue if the entire town of Plymouth tried 
to leave at once. Most Massachusetts residents are familiar with the 
monumental traffic problems caused by Cape Cod traffic on a summer weekend. 
Snarls such as these would almost certainly be dwarfed by those resulting from 
a full-scale evacuation of the Pilgrim EPZ. 

The number of cars on the road would also make it far more difficult for 
emergency workers and buses to get through to the school children and elderly 
who cannot transport themselves out of town. Ironically, the widespread 
availability of cars might prove the greatest obstacle to getting people out of 
the danger, zone in time to protect them from a radiation release. 

E. MOST RESIDENTS SURVEYED WANT PILGRIM TO REMAIN SHUT DOWN 
In light of the serious problems which beset the emergency plans and the 
^oor safetv record compiled by the Pilgrim plant, the residents surveyed have 
arrived at the following response to this situation: keep the plant shut down. 

17 



264 



When asked simply whether they favored reopening the plant after its 
scheduled maintenance and refueling, 55% said that it should remain shut down 
and only 34% favored reopening (Q. 25). When those who had not answered "shut 
down" were informed that the NRC had found serious management and safety 
problems at the Pilgrim plant, more than half changed their answer and said 
that if those findings were correct, the plant should remain shut down. 

Combining the responses to these two questions, 79% of the entire survey 
sample favored shutdown in response to either Question 25 or 26, with just 17% 
still favoring operation of the plant after be:ing asked both questions. 
Significantly, this response held true across all political and demographic 
categories: liberals and conservatives, young and old, high-school- and 
college-educated people, residents of all four towns, and even households 
containing Boston Edison employees favored shutdown of Pilgrim (Q. 25 & 26: 
Combined Answer). 

Thus, a clear majority of Pilgrim-area residents already favor shutdown 
of the Pilgrim nuclear power plant. After learning more about official views 
of the plant's safety, they favor shutdown by nearly a five to one margin. 

Much of this sentiment can be attributed to lack of faith in Boston 
Edison. When asked who they would trust for information and advice during an 
emergency, our survey sample expressed the greatest distrust for Boston Edison 
officials. Thirty-one percent said they would have no confidence in their 
advice; the next highest negative rating was 17%. Boston Edison also had the 
second-lowest positive rating (coming in just ahead of the faceless 
"independent expert") and the lowest overall confidence score (Q. 23). 



18 



265 



Hi. DETAILED SUMMARY OF QUESTIONS AND RESPONSES 
A. METHODOLOGY 

The survey is based on 363 telephone interviews with adult residents of 
che towns of Plymouth (including Manomet), Carver, Duxbury and Kingston. These 
towns comprise the emergency planning zone for the Pilgrim Nuclear Power 
Station. 

The questionnaire consisted of 3A questions, including eight questions on 
demographic variables. Interviewing was conducted from May 5 to May 14, 1987, 
by MASSPIRG researchers acting under the supervision of a John F. Kennedy 
School of Government graduate student trained in scientific polling methods. 

Telephone numbers for interviews were chosen randomly by computer in order 
to reach residents with unlisted phone numbers and new residents whose numbers 
had not yet been published. This technique yields a more representative sample 
of households than use of a telephone directory to generate numbers. 

The survey was a stratified random sample. This technique divides the 
total population into twelve groups, known as strata, each of which consists of 
men or women of a given town or telephone exchange. Within each of these 
strata, individual respondents were selected totally at random. The number of 
interviews conducted in a given stratum was determined in advance, according to 
the proportion of the total actual population represented by that group and in 
order to produce a statistically s- sni /^icant 'laiiple frrm each tcwn. Tne 
results veve then weighted based on the share of actual population represented 
by each stratum; the totals thus refect the disLribution by town and gender of 
the actual population, not of the sample population. 

In theory, 95 times out of 100 the results from the overall sample should 
differ no more than 4 percentage points from what would have been found by 
purveying the entire population of the towns. The sampling error for smaller 

19 



266 



eubgroups (for example, a particular age group, or residents of one of the 
towns) could be larger, depending on the size of these groups. Other errors 
can result from the usual practical problems of conducting a public opinion 
survey. 

B. THE SURVEY 



Question 1 . DID YOU KNOW THAT THE STATE AND LOCAL GOVERNMENT HAVE DEVELOPED AN 
EMERGENCY EVACUATION PLAN TOR YOUR TOWN IN THE EVENT OF A SERIOUS 
ACCIDENT AT THE PILGRIM NUCLEAR POWER STATION? 





Total 
Numbei 


Responses 
r % 


Kingston 

Number 


% 


Age 65 an< 
Number 


i Over 
% 


Yes 


314 


87 


37 




80 


40 


74 


No 


49 


13 


10 




20 


14 


26 



This threshold question revealed that most respondents were aware of the 
existence of emergency planning for their community. In Kingston, however, 20% 
of those surveyed did not know that there is an emergency evacuation plan for 
their town, and among respondents who are 65 and older, more than one-fourth 
answered "no" to this question. 

Question 2 . IF THERE WERE A SERIOUS ACCIDENT AT THE PILGRIM NUCLEAR POWER 
PLANT HOW DO YOU THINK THE AUTHORITIES WILL WARN PEOPLE? 
(list all responses) 



Siren 

TV / Radio 
Other 
Don't Know 

The correct answer, presented on page 1 of the official emergency planning 
booklet, is that warnings will go out via civil defense sirens, police 
loudspeakers, and local radio and television stations. While three-fourths of 
the respondents named sirens as one warning mechanism, fewer than one in five 
were aware that warnings would be issued over television and radio. Again, 

20 





% 


of Total 


Number 


Responses 


272 




75 


70 




19 


34 




9 


38 




10 



Number 


% 
Re 


of Total 
isponses 


286 




79 


72 




20 


3 




1 



267 



those over 65 displayed the leajt awareness of emergency procedures (only 6A% 
mentioned warning sirens, just 6% named TV/radio, and 14% did not know how they 
would be warned). 

Question 3. HAVE YOU EVER HEARD THE PIT, GRIM WARNING SIREN? 



Yes 

No 

Don't Know 

.he qui:cj.on, hIZ U^O) said they have heard the 
siren once or twice, 29% (82) have heard it 3 to 5 times, and 17% (48) have 
heard it go off more than 5 timas. Twelve percent (36) did not say how many 
times they had heard the siren. 

More than a third of the Carver residents surveyed (36%) had never heard the 
warning siren, while 86% of Plymouth residents reported having heard it at 
least once. Those living in the area for 3 years or less are least likely to 
have heard the siren — only 50% of those surveyed answered "yes." 

Q uestion 4 . HOW WELL CAN YOU HEAR THE PILGRIM WARNING SIREN AT YOUR HOME WHEN 
THE WINDOWS AND DOORS ARE CLOSED? 

% of "Yes" 
Numbe r to Q. 3 

Well 95 33 

Somewhat well 37 13 

Not well 75 26 

Not at all 44 15 

Don't Know 40 lA 

Only 46% of those who had hearr, the sir^n said that they could hear it well or 
;iomewhat well when the doorr and .■:-''^"s of thrir hoves were closed. 
demonstrating the need for additional ways of warning residents in case of an 
emergency. 



21 



268 



Question 5 . CAN YOU HEAR POLICE. FIRE OR AMBULANCE SIRENS AT YOUR HOME WHEN 
YOUR WINDOWS AND DOORS ARE aOSED? 



Yes 

Sometimes 

No 

Don • t Know 



Number 


% 
Re 


of Total 
isponses 


273 




75 


49 




13 


36 




10 


1 








Question 6 . WHAT DOES IT MEAN WHEN THE PILGRIM SIREN GOES OFF? 



Accident 
Drill 
Other 
Don't Know 



Number 


% 
Re 


of Total 
isponses 


109 




30 


70 




19 


118 




33 


77 




21 



"Other" answers included many "evacuate," "head for the hills," "start 
packing," and "kiss your ass goodbye," indicating that respondents would think 
an accident was in progress at the Pilgrim plant. (The f rivolousness or 
sarcasm in some of these responses indicates that many residents either 
do not take the sirens seriously or do not believe warnings would be of any use 
were a serious accident to occur,) Another group of "other" answers, such as 
"another thunderstorm," indicated the belief that hearing the siren simply 
means the warning equipment is malfunctioning. 



Question 7 . IF YOU HEARD A SIREN RIGHT NOW, DO YOU THINK YOU COULD TELL THAT 
IT WAS BECAUSE OF PILGRIM, RATHER THAN, SAY, A FIRE ENGINE, AN 
AMBULANCE. OR SOMETHING ELSE? 

% of Total 



Yes, could tell 
Probably could 
Probably could not 
No, couldn't tell 
Don't know 



Number 


Res 


ponses 


215 




59 


35 




10 


11 




3 


77 




21 


15 




A 



22 



269 

Again. Carver residents exhibited the least amount of familiarity with the 
Pilgrim warning sirens: nearly half — 45% — answered that they could not or 
probably could not distinguish the Pilgrim siren from a fire engine or an 
ambulance. Also, one-third of respondents aged 65 and over expressed doubt 
that they could recognize the Pilgrim siren. 

Question 8 . HOW WOULD YOU RECOGNIZE THAT A SIREN MEANT A NUCLEAR ACCIDENT? 

% of Those Answering 
Number Q. 7 Affirmatively 

High pitch 25 10 

Steady tone 26 10 

Very loud 42 16 

Persistent 30 11 

Other 91 35 

Don't know 61 23 

Although a majority of respondents answered that they would recognize the 
Pilgrim siren if they heard it (Q. 7), few respondents correctly explained 
how they would tell whether a real accident were taking place. The nuclear 
warning siren will be distinguishable from others by its duration (15 minutes), 
or its "persistence." Only 11% of respondents gave this answer. The most 
common responses of those categorized under "other" were that the siren has a 
"fluctuating" or "pulsating" tone, or simply that "you could just tell." 

Question 9 . HAVE YOU OR ANYONE IN YOUR HOUSEHOLD RECEIVED A COPY OF THE 

BOOKLET CALLED "EMERGENCY PUBLIC INFORMATION: WHAT TO DO IN CASE 
OF AN EMERGENCY AT PILGRIM NUCLEAR POWER STATION"? 

Total Responses New Residents (<3 yrs) 

Number % Number % 

Yes 203 56 

Not sure / maybe 42 11 

No 104 29 

Don't know 11 3 4 4 

Although Boston Edison claims to have distributed copies of this booklet to all 
residents of the emergency planning zone in November 1986, nearly one-third of 
those we surveyed (29%) had not received a copy, and another 11% were not sure 
if they had received one. These distribution problems were most critical with 
regard to people living in the area for 3 years or less, who made up nearly a 
quarter of the survey sample: 47% of these respondents had not received the 
emergency planning booklet, compared to only 41% who were sure they had. 

23 



33 


41 


6 


7 


39 


47 



270 



Question 10 . WOULD YOU SAY YOU HAVE READ THE BOOKLET COMPLETELY. PARTIALLY. OR 
NOT AT ALL? 





Number 


% 


of 


"Yes" 01 

to Q. 


: "Maybe" 


% 
Re 


of Total 
:sponses 


Completely 


82 






33 






23 


Partially 


109 






44 






30 


Not at all 


45 






18 






* 



Among those who said they had received or may have received the emergency 
planning booklet, a full 62% admitted that they had read it only partially or 
not at all. In other words, only 23% of the total surveyed said they had read 
the booklet completely. The lack of actual knowledge of emergency procedures 
that this implies is corroborated by the answers to many other questions in 
this survey. 

* The number who have not read the booklet is actually much larger than 45, 
since this question was not asked of those who never received the booklet. 

Question 11 . IN CASE YOU HEAR THE WARNING SIREN. INDICATING A SERIOUS PROBLEM 
AT PILGRIM. WHAT IS THE VERY FIRST THING THAT YOU WOULD DO? 



Turn on radio or TV 

Take shelter at home 

Get family together 

Make phone calls 

Start packing 

Evacuate 

Other* 

Don't know 

* Common responses include: 

"Panic" (5 respondents) 
"Pray" (6) 

"Kiss my wife/husband" (2) 
"Get drunk/grab a six" (6) 

This question was designed to find out what people would in fact do. as opposed 
to what they think they are supposed to do. Only 10% said that they would take 



Number 


% 
Re 


of Total 
isponses 


65 




18 


37 




10 


42 




12 


32 




9 


9 




2 


99 




27 


66 




18 


42 




12 



24 



271 



shelter at home, as the emergency planning booklet directs on page 3; only 18% 

said they would turn on the radio or TV to get information or instructions, 

which the booklet also recommends (there is a degree of overlap in these 

figures, as some respondents gave more than one answer). 

Significantly, the most frequently named response was "evacuate," and a number 
of other responses — such as "start packing" and many responses categorized 
under "other" — were premised on immediate evacuation, contradicting the 
express directions in the emergency planning booklet. 

Question 12 . DO YOU KNOW WHAT THE OFFICIAL EMERGENCY H.AN RECOMMENDS THAT YOU 
DO TO GET SPECIFIC INSTRUCTIONS IN CASE OF AN EMERGENCY? 

% of Total 
Numbe r Responses 

Yes: turn on radio/TV 120 33 

Yes: other 31 9 

No 206 57 



Only one in three respondents knew the correct response, "tune to local radio 
and TV stations," which is listed on page 3 of the emergency information 
booklet. Even more disturbing, fewer than one in five respondents 65 or over 
(19%) gave the correct response to this question, reiterating the concern that 
the elderly may present difficult problems for emergency planners. 

Question 13 . WOULD YOU USE THE TELEPHONE TO FIND OUT EMERGENCY INFORMATION OR 
TO FIND OUT INFORMATION ABOUT FAMILY MEMBERS? 



Number 


% of Total 
Responses 


226 
117 


62 
32 



Yes 

No 

Don't knew 16 4 

Surprisingly, the emergency information booklet does not advise people not to 
use the telephone in case of an emergency. Accordingly, nearly two-thirds of 
those we surveyed said that they would use the phone — primarily to call the 
police for information or to try to contact family members. In all likelihood, 
this will only serve to tie up phone lines and jeopardize efficient execution 
of the emergency plans. 



25 



272 



Question 14 . IF THERE WERE AN ACCIDENT AT PILGRIM AND YOU WERE TO ACTUALLY 
EVACUATE YOUR HOME. WHERE WOULD YOU GO? 









% 


of Total 






Number 


Responses 


Hanover Mall 




46 




13 


Bridgewater State Colle 


•ge 


20 




5 


Taunton State Hospital 




3 




1 


Elsewhere in Mass. 




91 




25 


Wherever directed 




7 




2 


Other* 




119 




33 


Don't know 




65 




18 



* Representative responses include: 

"Whichever way the wind isn't blowing" 

"Roads would be jammed up/would never get out of town" 

"Alaska/Canada/Califomia/Vermont/Miseissippi" 

"Good questioni" 

Only 19X of the respondents said they would go to one of the evacuation centers 
named in the emergency information booklet (the first three responses listed 
above). IVo-thirds of these people (13X) would go to the Hanover Mall, which 
has already pulled out of the evacuation plan and will not serve as a reception 
center, but which is still listed as one in the booklet. 

It is clear from these responses that a real evacuation would produce chaos. 
Only 22 of those surveyed would listen first for directions, confirming the 
conclusion suggested by Question 12 that few people would know to wait and tune 
in to local media for emergency information. Moreover, many of those who 
profess knowledge of the actual plans are misinformed: for example, two-thirds 
of the Carver residents who said they would go to an evacuation center named 
the wrong one. 

Even those supposedly "in the know" evidenced a shocking lack of confidence in 
the evacuation plans. Although the- sample size is admittedly very small, only 
2 of 15 respondents from households containing Boston Edison employees and only 
4 of 20 from households containing someone responsible for implementing the 
evacuation plans said they would go to one of the evacuation centers in case of 
an accident at Pilgrim. 



26 



273 



Question 15 . DO YOU KNOW WHAT ROUTE YOU ARE SUPPOSED TO TAKE TO GET THERE [TO 
THE EVACUATION CENTER]? 

% of Those Who Said They 
Number Would Go To an Evacuation Center 

Yes A3 62 

No 23 3A 

This question tested the knowledge of the evacuation routes mapped out in the 
emergency information booklet (pp. ^-5) among those respondents who said, in 
response to Question lA, that in case of an emergency they would go to one of 
the evacuation centers. Even among this self-selected group, one-third 
admitted that they did not know the recommended route. 

Question 16 . DO YOU HAVE ANY CHILDREN AGE 16 OR YOUNGER WHO GO TO SCHOOL IN 
THE AREA? 

% of Total 
Number Responses 

Yes 13A 37 

No 226 62 

Question 17 . ARE THERE ANY TIMES AFTER SCHOOL HOURS WHEN YOUR CHILD (REN) 
IS (ARE) NOT IN THE CARE OF AN ADULT? 

% of "Yes" to 
Number Q. 16 

No 83 62 

Yes 50 37 

In case of an emergency at Pilgrim during after-school hours, as many as 37% of 
children 16 or under could be left to fend for themselves. Parents at work 
during these times "may not be permitted to return [to the affected areas] 
during the evacuation," according to the anergency information booklet (p. 6). 

Question 18 . IF THERE IS AN ACCIDENT AT PILGRIM DURING SCHOOL HOURS, WHAT 
WOULD YOU DO ABOUT YOUR CHILD (REN)? 

Z of "Yes" to 
Number Q. 16 

Get children from school 65 A8 

Wait for them to come home A 3 

Meet them outside danger zone 13 9 

Other 27 20 

Don't know 22 17 



27 



274 



The correct answer, "meet them outside the danger zone," was given by only 9% 
of the respondents. The most common response was to go get the children from 
school oneself, which people are explicitly instructed not to do on page 6 of 
the emergency planning booklet. The response to this question clearly 
indicates either a major flaw in the evacuation plans or the need for intensive 
education to convince parents to ignore their strong impulse to find their 
children themselves. 



Question 19 . ACCORDING TO THE OFFICIAL EMERGENCY PLAN. YOU ARE SUPPOSED TO 

MEET THEM AT A SPECIAL EVACUATION CENTER AWAY FROM TOWN. DO YOU 
HAPPEN TO KNOW WHERE THE CENTER IS WHERE YOU WOULD FIND YOUR 
CHILD (REN)? 

% of "Yes" to 
Number Q. 16 

Yes 39 29 

No 92 69 

Adding to the confusion and panic that an evacuation would cause, seven out of 
ten parents we surveyed would not know where to find their children if an 
accident occurred at Pilgrim during school hours. 

Question 20 . DO YOU HAVE A CAR AVAILABLE FOR YOUR USE DURING . . . 

Total Responses Age 65 & Over 
Number % Number % 



WEEKDAYS? 










Yes 


344 


95 


49 


90 


No 


11 


3 


5 


10 


Sometimes 


5 


2 








WEEKNIGHTS? 










Yes 


340 


94 


47 


88 


No 


13 


3 


6 


12 


Sometimes 


4 


1 








WEEKENDS? 










Yes 


343 


94 


49 


90 


No 


9 


2 


4 


7 


Sometimes 


A 


1 


1 


2 



At any given time, 95% of the households in the emergency planning zone would 
have a car available to be used. This many households each evacuating in a 
separate automobile at the same time will likely create traffic problems of 
unprecedented proportions, particularly in light of the fact that most people 
surveyed would not knew to use the evacuation route planned for their 
particular section of the EPZ (see questions 14 and 15) . 

Respondents 65 and over were the only demographic group without such wide 
access to an automobile. 7 to 12% of those we surveyed would not be able to 



28 



275 



use a car at any given time, creating a different set of problems for 
evacuating this group of residents. 



Question 21 . DOES YOUR HOME HAVE A BASEMENT? 



Yes 
No 



Question 22 . SUPPOSE YOU WERE ADVISED TO EVACUATE BECAUSE OF AN ACCIDENT AT 
PILGRIM. BUT YOU HAD CHILDREN IN SCHOOL OR A FAMILY MEMBER IN A 
HOSPITAL OR NURSING HOME. ACCORDING TO THE PLAN, YOU ARE 
SUPPOSED TO GO DIRECTLY TO A SPECIAL EVACUATION CENTER, WHILE 
YOUR FAMILY MEMBERS WERE TRANSPORTED TO THEIR APPROPRIATE 
LOCATIONS. WOULD YOU BE ABLE TO FOLLOW THESE INSTRUCTIONS? 



Number 


% of Total 
Responses 


313 
A7 


86 
13 



Number 


% of Total 
Responses 


185 
128 


51 
35 



Yes 

No 

Don't know A2 12 

This question is similar to the one asked of parents of school-age children 
(Question 18), but is far less open-ended and more likely to elicit a "yes" 
response. First, the question is hypothetical — most respondents did not in 
fact have children in school or family members in a hospital or nursing hone. 
Second, the question spells out what the actual evacuation plans are in a way 
that makes them sound reasonable and workable. Finally, the question asks 
whether the respondent "would be able" to comply with such a scheme if 
instructed to do so. 

In spite of the clear slant of this question, nearly half those surveyed said 
that they either would not follow these plans or did not know whether they 
could follow them. The vast majority of those answering "no" mentioned their 
need to provide for the safety of their family members themselves and not to 
entrust that role to the authorities. As was clear with Q-jastion 18, the 
strong desire of people to find their family members indicates either a major 
flaw in the evacuation plans or the need for far better education on behalf of 
Boston Edison. 



29 



276 



Q uestion 23 . IF THERE WERE Mi ACCxji^.f A'^ PiLGRIK. YOU t-IIGHT HEAR STATEMENTS 

ON THE RADIO OR OK 1/ "Y l/I I'^ RENT .'EOPLE AND ORGANIZATIONS. I'M 
GOING TO MENTIOn S0.~; CT IHF.M. AND AS I DO. PLEASE TELL ME FOR 
EACH ONE HOW MUCT CO:" J'' ""Cn YOU WOULD HAVE IN THEM TO GIVE YOU 
ACCURATE INFO KMAT low A:ID COOu AJ)VICE. A SCORE OF 5 MEANS THAT 
YOU HAVE A GREAT D' '', OF COiriDI^NCE IN THEM; A SCORE OF 1 MEANS 
THAT YOU HAVE MO OJ'.'l'Il'lznr^ I!' T.iSIR /J3VICE; A SCORE OF 3 WOULD 
BE SOMEWHERE If! ''.i::^, >rB'i..':. 



Governor Dukakis 

An official of Boston 
Edison 



tIJII 




3" 


\nt 


:'ering 
I12II 


"1" 


DK 


Avei 
Sec 

3 


-age 
3re*a 


36 


-> - 


.r 




6 


17 


2 


54 


19 


• -} 


io 




ii 


31 


2 


2 


81 



An official of the U.S. 34 
Nuclear Regulatory Comm. 



16 



3.51 



Attorney General Shannon 19 
An independent expert 15 



12 

17 



18 
10 



3.30 
3.01 



Boston Edison received easily t-, : ,l -ar'.;- of any of the people or 
organizations we mentioned, garr^rin,^ ^.,e r.econd-lowest positive rating, far 
and away the highest negative ci"c; :...'. the Iciest average score. Even among 
those respondents who believ3 t".".t ?il~r'.tp chould reopen despite findings of 
serious safety problems (see Que. tier. -3 25 c-^ 26), only 32% expressed a great 
deal of confidence in emergency i~for.i9tior dissemin?.ted by Boston Edison. 

* "Average Score" was computed exclu'! '.ji[; those ans-.jering "don't know" or who 
refused to answer. Thus, Attorney G-n^ral Shannon's 3.30 score must be 
tempered by the fact that 18% did not knov. '•]'.''-': a-iount of confidence they would 
have in him. 



Question 24 . DO YOU THINTC TH/.T IT TS LIKELY 
ACCIDENT AT THE riLC-.xi: FLA>i7: 



rH/T THERE WILL BE A SERIOUS 



% of Total 
Responses 



Yes 



24 



Maybe 
No 



7-1 



.20 
',6 



Don't know 



31 



Nearly half — 44% — of thos= s 
Pilgrim is either likely or at It .1 
across the political spectrum: '• " ' c* 



L.i*. . cJ: -t 1 serious accident at 
":i'Sli3. Tliis viewpoint held true 
-"..■■-fle"cribed conservatives, 44% of 



277 



liberals, and 51% of moderates answeved either "yes" or "maybe" to this 
question. 

Interestingly, of those who believed that Pilgrim should not be reopened (see 
Questions 25 and 26), only 53% thought a serious accident is likely or may be 
likely. This total is just slightly larger than the total sample's response to 
Question 24, suggesting that opposition to Pilgrim runs deeper than simply fear 
of a serious accident. Other issues that may be generating public 
dissatisfaction with the Pilgrim plant probably include waste disposal, smaller 
scale radiation releases, and unreliability. 



Question 25 . PILGRIM IS CURRENTLY SHUT DOWN FOR MAINTENANCE AND REFUELING. IN 
YOUR OPINION, SHOULD THE PLANT BE REOPENED OR SHOULD IT REMAIN 
SHUT DOWN? 





% 


of To 


tal 


Number 


Re 


:sponses 


123 




34 




200 




55 





Reopened 

Shut Down 

Other 15 4 

Don't Know 24 7 

Over half of those polled want Pilgrim to remain shut down, while only a third 
believe the plant should reopen. As with the responses to Question 24, this 
sentiment cut across political lines: 51% of conservatives, 60% of liberals, 
ana 59% of moderates favored shutdown. 

An interesting footnote to these figures was the response of people from 
households with either a Boston Edison employee or someone responsible for 
implementing the emergency plans (15 and 20 respondents, respectively). While 
these figures are not statistically significant, it is nevertheless noteworthy 
that a fifth of the respondents from each of these groups favored unequivocal 
shutdown of the Pilgrim plant. 

Question 26 . STUDIES RECENTLY COMPLETED BY THE U.S. NUCLEAR REGULATORY 

COMMISSION SHOW INDICATIONS OF MANAGEMENT AND SAFETY PROBLEMS AT 
PILGRIM, MAKING IT ONE OF THE MOST DANGEROUS NUCLEAR PLANTS IN 
THE COUNTRY. IF THESE FINDINGS ARE CORRECT, IN YOUR OPINION 
SHOULD THE PLANT BE REOPENED OR SHOULD IT REMAIN SHUT DOWN? 

% of Non-"Shut Down" 
Number Responses to Q. 25 

Reopened 60 37 

Shut Down 88 54 

Other 5 3 

Don't Know 5 3 



31 



278 



This question, asked only of those not answering "shut down" to Question 25, is 
obviously a more loaded question and for that reason was the last question 
asked in the survey, so as not to taint the other responses. Only slightly 
more than a third of those who initially favored reopening Pilgrim still 
believed the plant should reopen in light of the NRC's findings regarding 
safety and management problems. The turnaround was most dramatic among those 
who had lived in the area for three years or less, a group making up 23X of our 
total sample. 77% of these respondents ans^vered "shut down" to this question 
(compared to 54% on Q. 25), suggesting that many newer residents simply are not 
yet fully informed about the problems that have historically plagued the 
Pilgrim plant. 



Questions 25 and 26: CO! £ IKED 



Numbe r 



% of Total 
Responses 



Answered "Shut Down" to 
Q. 25 or Q. 26 



288 



Answered "Reopen" to Q. 26 



60 



Less than one in five respondents was unequ:vocally in favor of reopening the 
Pilgri"! plant. The overwhelming sentiment in favcr of shutting down an unsafe 
nuclear power plant was consistent across all demographic lines: 

* all four towns in the survey favored shutdown by margins ranging 
from 74% (Carver) to 90% (Kingston); 

* self-described conservatives were 77% in favor of shutdown, 
compared to 84% for liberals, 82% for moderates, and 72% for those 
who could not or would not describe their political orientation; 

* the only age group coming in at less than 70% was the 65 and over 
group, 66% of whom favored shutdown; 

* educational backf^rour.d slso had little effect on shutdown 
sentiment: the percentag'is in fcvor of shutdown varied only between 
75 and 83% when the survey sample was grouped by educational level; 

* even among those from households containing Boston Edison 
employees or those with official responsibilities for ir n1 ementing the 
emergency plans, respondents favoring shutdown outnumbered those in favor of 
reopening the plant by approximately 5 to 3. 



32 



279 



IV. RECOMMENDATIONS 
Our survey of Pilgrim area residents shows a widespread lack of knowledge 
about emergency planning procedures, little faith among the population that 
the evacuation plans are workable or worth complying with, strong indications 
that any attempt at immediate evacuation would meet with little success, and a 
broad consensus behind the idea that a nuclear plant with a safety record like 
Pilgrim's should remain shut down. These conclusions are surprising only to 
the extent that they present an even poorer picture of emergency preparedness 
than was revealed in the last MASSPIRG survey. 

MASSPIRG and a variety of other citizen groups and local and state 
officials have consistently argued that the Pilgrim emergency plans are 
themselves a disaster. With the rapid population growth in the Plymouth area 
and the withdrawal of the Hanover Mall as an evacuation center, the plans have 
deteriorated even further. FEMA has withdrawn its approval of the plans, 
calling them "inadequate to protect the public health and safety in the event 
of an accident." Yet Boston Edison is nonetheless considering restarting the 
plant without locally and federally approved plans. 

The findings in this report clearly demonstrate that restarting the plant 
under the existing emergency plans could prove disastrous. Given the current 
level of public information about the plans, they would not be adequate to 
protect the public health and safety even if the deficiencies identified by 
FEMA were corrected. Moreover, because residents responded that they would 
refuse to comply with key elements of the plans, there is a serious question as 
to whether any plans, no matter how good they looked on paper, could be 
effectively implemented. 

In light of these results and the serious management and safety problems 
still remaining at Pilgrim, we strongly recommend that the Pilgrim plant should 
not reopen until it is determined that: 

33 



280 



(1) workable plans can be developed; 

(2) such plans have been effectively implemented and communicated to the 
public; and, 

(3) existing management, safety and economic concerns have been 
adequately addressed. 

We call on Governor Dukakis, the State Legislature, and the Massachusetts 
congressional delegation to do everything within their power to keep the 
reactor closed until the above conditions have been met. 

In the meantime, MASSPIRG continues to recommend that the State and Boston 
Edison explore the possibility of alternatives — such as efficiency reforms, 
cogeneration. small power producers, and conservation — which have the 
potential to produce energy more safely, cheaply and efficiently than does the 
Pilgrim nuclear power plant. 



i 



34 



281 



NUCLEAR LEMON 



PUmu OPETVkTIQN vs. nETfEMEMr 



I9a7 4 





UTTX 



ES 



RATEPAYER SAVINGS FROM RETIRING 
THE PILGRIM NUCLEAR POWER PLANT 



Massachusetts Public Interest Research Group 
(MASSPIRG) 



NOVEMBER 1987 



282 



NUCLEAR LEMON 



RATEPAYER SAVINGS FROM RETIRING THE 
PILGRIM NUCLEAR POWER PLANT 



Massachusetts Public Interest Research Group 

(MASSPIRG) 

29 Temple Place 

Boston, MA 021 11 

(617) 292-4800 



Research Director and Author: 

Alan J. Nogee 

Research Assistant: 

Susan Boehm 



November 1987 



283 



ACKNOWTLEDGMENTS 

The author gratefully acknowledges the assistance of Susan Boehm, a 
graduate student at the John F. Kennedy School of Government. Thanks 
also to Stephen Bernow, of the Energy Systems Research Group, David 
Schlissel, of Schlissel Engineering Associates, and Chris Granda, of the 
Legislative Energy Committee for invaluable technical input. Armond 
Cohen, of the Conservation Law Foundation; Joshua Kratka, Rachel 
Shimshak, Michael L'Ecuyer, and WiUiara Ryan, of MASSPIRG; and 
Deborah Horvitz, my wife, provided helpful editorial comments on early 
drafts of this work. 



ABOUT THE AUTHOR 

Alan Nogee has been an Energy Policy Analyst for over ten years. He is 
author of two major national reports on utility policy - Rate Shock: 
Confronting the Cost of Nuclear Power, and Gambling for Gigabucks: Excess 
Capacity in the Electric Utility Industry ~ and numerous articles. He has 
testified or spoken by invitation to the energy committees of the U.S. Senate, 
House of Representatives, National Governors' Association, National 
Conference of State Legislatures, and regulatory agencies and legislative 
committees in several states. Before joining MASSPIRG in May, 1987, he 
was an Energy Analyst with Environmental Action Foundation, in 
Washington, D.C., and for consumer and environmental groups in 
Philadelphia, Pennsylvania. 



284 



TABLE OF CONTENTS 



1. Introduction -- Nuclear Costs and Cancellations 1 

2. The High Cost of Operating Pilgrim 4 

A. Edison ignores nuclear cost trends 5 

B. MASSPIRG assumptions are still conservative 7 

3. Economic Benefits of Retiring Pilgrim 8 

A. Replacement power costs less than Pilgrim 8 

B. Other shutdown costs 10 

C. Ahemative scenarios show savings from retiring Pilgrim 12 

4. Conclusions and Recommendations 15 

Appendix A. Annual Costs of Pilgrim vs. Alternatives 16 

Appendix B. MASSPIRG Nuclear Cost Estimates 23 

Appendix C. Causes of Nuclear Cost Escalation 29 

Notes 32 



LIST OF FIGURES 



Figure 1. Pilgrim Capital Cost 2 

Figure 2. Electricity Generation cost -- 1988 3 

Figure 3. Pilgrim Capital Cost Projection (BECO Assumptions) 3 

Figure 4. Pilgrim Cost Components (BECO Assumptions) 4 

Figure 5. Pilgrim Annual Generation Costs (Alternative) 6 

Figure 6. Pilgrim Total Costs (Alternative) 7 

Figure 7. Alternative Project Fuels 9 

Figure 8. Pilgrim vs. Alternative Annual Generation Costs 9 

Figure 9. Pilgrim vs. Replacement Power Costs (BECO Assumptions) 10 

Figure 10. Pilgrim Operation vs. Retirement (BECO Assumploins) 11 

Figure 11. Pilgrim Operation vs. Retirement (Present Value) 13 

Figure 12. Cumulative Savings from Retiring Pilgrim 14 

Figure 13. Savings from Retiring Pilgrim (Sensitivity to Sunk Costs) 14 

Figure 14. National Average Capital Additions 23 

Figure 15. Pilgrim & National Average Capital Additions 23 

Figure 16. Capital Additions Projections 24 

Figure 17. Cumulative Savings from Retiring Pilgrim (Sensitivity to Capital Additions) 24 

Figure 18. Pilgrim vs. National Average O&M Costs 25 

Figure 19. O&M Cost Projections 26 

Figure 20. Cumulative Savings From Retiring Pilgrim (Sensitivity to O&M Costs) 26 

Figure 21. Pilgrim vs. National Average Capacity Factor 27 

Figure 22. Capacity Factor Projections 27 

Figtire 23. Cumulative Savings from Retiring Pilgrim (Sensitivity to Capacity Factor) 28 



LIST OF TABLES 



Table 1. Alternative Assumptions Used in MASSPIRG Projections 12 

Table 2. Additional Conservatisms in All Scenarios 12 

Table 3. Savings to Ratepayers From Retiring Pilgrim 13 

Table 4. Oldest U.S. Operating Nuclear Reactors 31 

Table 5. Retired U.S. Reactors 31 



285 



EXECUTIVE SUMMARY 



This study examines the costs and 
benefits of permanently closing the 
Pilgrim nuclear plant, and replacing it 
with alternatives that are currently avail- 
able to Boston Edison (BECO). Using 
conservative assumptions which are likely 
to underestimate Pilgrim's costs, and to 
overestimate the cost of alternatives, 
MASSPIRG has found that: 

1. Utility customers would save at least 
$1.5 billion (present value) over the next 
25 years by closing Pilgrim, if future 
Pilgrim costs were to follow historical 
trends for the plant. These savings would 
occur even if ratepayers had to pay for the 
full utility investment in the plant to date, 
including the same profit the companies 
would have earned if the plant had 
operated. 

2. K trends at Pilgrim improved to the 
most optimistic levels that could 
reasonably be hoped for, utility customers 
would still save money by retiring Pilgrim, 
even if they had to pay for the full sunk in- 
vestment in the plant. 

3. Even under Edison's own assump- 
tions, which are unrealistic, ratepayers 
would likely benefit from Pilgrim retire- 
ment, if the Massachusetts Department of 
Public Utilities required utility customers 
and investors to share the cost of past in- 
vestment in Pilgrim according to tradition- 
al regulatory practice. 

This study starts with the same figures 
and uses the same methods of analysis 
employed by BECO in a recent presenta- 
tion to the Massachusetts Executive Of- 
fice of Energy Resources (EOER). The 



utility's assumptions about fumre 
Pilgrim performance and major costs 
are compared to past performance and 
cost trends at Pilgrim and other U.S. 
nuclear plants, and alternative assump- 
tions and cost projections are 
developed. 

In order to err on the side of underes- 
timating Pilgrim costs, MASSPIRG 
uses a number of unrealistically low 
Edison estimates in all projections. The 
costs of nuclear fuel, nuclear waste dis- 
posal and of dismantling Pilgrim at the 
end of its operating life are unchanged 
from BECO projections. It is assumed 
that the 15-year-old Pilgrim plant could 
operate for a total of 40 years, although 
no nuclear plant has operated for 
longer than 26 years. To be as favorable 
to Pilgrim as possible, MASSPIRG also 
assumes that the cost of replacement 
parts and safety upgrades will level off, 
and that Pilgrim performance will not 
deteriorate with age. 

Replacement power for Pilgrim is 
readily available from at least two sour- 
ces. First, Pilgrim's owners could 
"mine" electricity that is currently 
wasted by inefficient lighting, applian- 
ces, and other electrical equipment. A 
report to Edison's Board of Directors 
indicated the potential to reduce the 
utility's electric demand by 1,000 
megawatts (Mw), at an average cost of 
less than two cents per kilowatt hour 
saved. Second, Pilgrim's owners could 
purcha.se electricity from small power 
producers and cogenerators. Indepen- 
dent power producers have bid to supp- 



286 



ly Boston Edison with 1,848 Mw by 19*^2. 
Pilgrim capacity is 670 Mw. 

While some of the independent 
facilities have environmental problems, 
the combined potential of the efficiency 
improvements and independent power 
producers could replace Pilgrim and meet 
Edison's projected demand growth with 
over 1,000 Mw to spare. In order to over- 
estimate the cost of replacing Pilgrim, it is 
assumed that all the efficieno,' savings go 
to displace demand growth, with the cost 
of power to replace Pilgrim based on a 
range of bids from cogeneration and 
small power facilities. 

The table and figure below summarize 
the savings to ratepayers from retiring 
Pilgrim under various assumptions. The 
"Pilgrim Optimistic Case" (most favorable 
to Pilgrim) combines the lowest 

PILGRIM OPERATION VS. RETIREMENT 
Present Value (Billjon_1937j)_ 



reasonanie level of Piigriin costs wnii 
the highest le^ei of replacenient powe^ 
costs. The "National Treno Case" as- 
sumes that the rate of escalating costs 
at pilgrim improves to the level o*" the 
average nuclear plant with Pilgrim's 
characteristics (age, type, location, 
etc. i. anu a moderate ieve! of replace 
ment power costs. Tne "Pilgrim f hston- 
cal Trend Case" assumes that Pilgrim 
cosl.^ coniiaue to escala'e at theii his- 
toric rat 3S, and assuines the lowest 
level of replacen.ent powei costs. 

All cases show savinf.? to ratepayers 
from retiring Pilgrim. M.^ SSPIRG 
therefore recommends that the Pilgrim 
njan' b' ^erf^''.r°'-*'^' c'osed. The 
Department of Public Utilities shou'.d 
allow no recovery of any f- ture utility 
investment 'u\ the plant. 




^1 






Repl. Power 



fptiffiistftr- 
S'^utdcwn 



Sunk 



SAVINGS TO RATEPA^'ERS FROM RETirJNG F O.GRIM 



pilgrim Historical 
Trend Case 

National 
Trend Case 

Pilgrim Optimistic 
Case 

BECO 



Ratepayei- Pa% 
SunkCt'ts 

$1.56bUriOn 
$813 million 
$49 million 
-$()lt millii'f 



I « ?stors Pay ; 
Sunk Costs j 

$2.28 biUiou 
Sl.54 billion 
$773 jiiillior! 
$168 miiiiori 



287 



1. Introduction - Nuclear Costs and Cancellations 



The Pilgrim nuclear power plant, in 
Plymouth, Massachusetts, is the focus of 
intense controversy over health and safety 
issues. (See, for example, No Exit: The 
MASSPIRG Sun'ey of Pilgrim Evacuation 
Planning, September 1987.) Relatively lit- 
tle attention, however, has been paid to 
the increasing cost of operating the 
Pilgrim plant. 

When Pilgrim was first turned on in 
late 1972, it appeared to be a relatively in- 
expensive source of electric power. Built 
for $232 million, Pilgrim's construction 
cost about three tirnes as much per 
idlowatt of capacity as an oil- fired plant. 
But uranium fuel was so much cheaper 
than oil, especially after the oil embargo 
of 1973, that the total cost of owning and 
operating the nuclear plant was less. 

It is worth noting that some nuclear 
costs — such as for research and develop- 
ment, fuel processing and insurance — 
were heavily subsidized by federal tax dol- 
lars. The Price-Anderson Act, passed by 
the U.S. Congress in 1957, limited in- 
dustry liability for nuclear accidents, 
thereby relieving it of having to consider 
fully the economic risks of nuclear genera- 
tion. Other costs ~ fo'' disposing of 
nuclear wastes and dismantling the plant 



at the end of its operating hfe (decom- 
missioning) -- could not be reliably es- 
timated then or now, since the required 
technologies still have not been 
demonstrated." 

During the 1970s, the co.st of build- 
ing new nuclear plants escalated 
dramatically. Nuclear construction 
costs increased by over twice the infla- 
tion rate, and nearly twice as fast as the 
f" St cf bi i! Jin;^ coi.i-fircd pLnts. 
Major causes of the increases included 
technical problems that were identified 
as nuclear plants gained operating ex- 
perience, new safety regulations im- 
posed by the Nuclear Regulatory 
Commission (NRC), and management 
failures to anticipate and respond ade- 
quately to these pressures. 

As a result of increasing nuclear con- 
struction costs, and a drop in electricity 
demand growth, many orders for 
nuclear plants were canceled in the 
1970s and 1980s. Over 110 nuclear 
plants - almost half of the total num- 
ber that utilities had ordered - were 
canceled in various stages of construc- 
tion, including a second unit planned 
for the Pilgrim site." 



'Power plant capacity is measured in watts. A kilowatt (Kw) is equal to 1,000 watts, enough power to light 
ten 100-watt light bulbs. A megawatt (Mw) equals one million watts or 1,000 kilowatts. An amount of 
electricity generated over a period of time is measured in kilowatt hours. A one megawatt plant operating 
at full capacity for 1 hour would produce 1,000 kilowatt hours (Kwh) of electricity. Pilgrim's capacity is 
670 MW, of which Boston Edisoa owns 74.27 p^rceat. OthLi owi.crs arc. Commonwealth Electric - 11 
percent. Eastern Utilities - 10.5 percent, Massachusetts Municipal Wholesale Electric - 3.73 percent, 
and Newport Electric - .5 percent. For simplicity, Pilgrim v-ill be treated in this report as it it were entire- 
ly owned by Boston Edison. 



288 



The same factors that caused construc- 
tion costs to skyrocket for new nuclear 
plants have also increased the costs of 
older plants. Large expenses have been re- 
quired for replacement equipment and 
safety improvements, called "capital addi- 
tions," and for major repairs. In addition 
to work needed to bring older plants up 
to new safety standards, many nuclear 
parts and systems have worn out sooner 
than expected. ^ For the U.S. nuclear in- 
dustry as a whole, capital additions in- 
creased by an average of 13 percent a 
year, after adjusting for inflation, between 
1970 and 1986. Operation and main- 
tenance costs increased by an average of 
over 11 percent a year, after inflation, 
during the same period. In addition, the 
majority of nuclear plants failed to per- 
form as reliably as their owners expected, 
experiencing many more shutdov.'ns than 
other types of power plants. 

As a result of these increasing capital 
and operating costs, some utilities have 
begun to take a hard look at the cost of 
continuing to operate nuclear plants. In 
March, 1986, the Washington Public 
Power Supply System (WPPSS) tem- 
porarily closed its two-year-old operating 
reactor because it was more expensive to 
operate than oil or gas-fired plants. In 
May, 1987, the Dairyland Power Coopera- 
tive, in Wisconsin, permanently shut 
down its 18-year-old LaCrosse nuclear 
plant because it was no longer competi- 
tive with alternatives. 

The Pilgrim nuclear plant has been 
subject to the same cost trends as other 
nuclear plants. In fact, between 1980 and 
1985, Pilgrim had the second most expen- 
sive capital additions per kilowatt of any 
nuclear U.S. power plant, .ind has be- 
come one of the most expensive nuclear 
plants in the country.^'' By the end of 
1987, Boston Edison (BECO) will have 



sunk S614 million into Pilgrim above its 
$232 million original cost, bringing the 
total investment in the plant to $846 
million (Figure 1). Even after adjusting 
for inflation, Boston Edison has spent 
40 percent more for replacement and 
new parts for Pilgrim than it initially 
spent building the plant. 

Largely as a result of these capital 
additions, Boston Edison's own es- 
timates show that in 1988, electricity 

Figure 1 

PILGRIM CAPITAL COST 
QQQ M[llion^^Nomina[) 




Year 



from Pilgrim will cost 6.53 cents per 
Kwh, almost twice as much as power 
from oil-fired plants, at a cost of 3.34 
cents per Kwh (Figure 2). 

BECO also recognizes that con- 
tinued Pilgrim operation will require 
ongoing capital additions. Edison es- 
timates that keeping Pilgrim running 
will require another $1.4 billion invest- 
ment in capital additions over the 25 
years it estimates for Pilgrim's remain- 
ing life. Pilgrim's total capital cost 
would then equal over $2.25 billion dol- 
lars - almost ten times the initial con- 
struction cost of the plant (Figure 3). 
Moreover, independent estimates dis- 
cussed in the following chapters of this 



289 



0.07 



Figure 2 

ELECTRICITY GENERATION COST -- 1988 
SperKWh 








report indicate that capital additions and 
other costs are actually likely to exceed 
BECO estimates. These escalating costs 
require serious consideration of whether 
continued investment in and operation of 
Pilgrim is economical. 

In April, 1986, the Pilgrim plant ex- 
perienced two "unexplainable automatic 
shutdowns," or "scrams." The NRC or- 
dered the plant to remain closed until 
serious problems with Pilgrim and its 



management are resolved. During this 
time, Boston Edison has chosen to 
make major upgrades in the Pilgrim 
plant ~ budgeting over $150 million in 
capital additions and nearly $100 mil- 
lion in maintenance costs in 1987 - to 
return the Pilgrim plant to service. This 
study looks at whether it makes more 
economic sense to retire Pilgrim than 
to continue investing hundreds of mil- 
lions of dollars in it. Chapter 2 looks at 
Boston Edison's projections of Pilgrim 
costs, compares BECO assumptions 
about nuclear cost trends to the histori- 
cal trends at Pilgrim and other nuclear 
plants around the country, and 
develops more realistic estimates of fu- 
*ure Pilgrim costs. Chapter 3 examines 
the cost of retiring the Pilgrim plant 
and replacing it with alternatives cur- 
rently available to Boston Edison. 
Chapter 4 summarizes the report's 
overall findings and presents 
MASSPIRG's recommendations. 



2.4 
2.2 

2 
1.8 _ 
1.6 _ 
1.4 
1.2 

1 
0.8 
0.6 4 
0.4 

0.2 i-S-B-&<5'-»-^'^ 



Figure 3 

PILGRIM CAPITAL COST PROJECTION 

BECO Assumptions - Bi llion $ (Nominal) 



cr-- 



^' 



.Ji 



ja^ 



i»72 iy// 



" ^ra82 TgST- ■ 1i»2^ 

Year 



Pilgrim Historical 



Tggy 2002 2007—201 2 

_ BECO Projection 



290 



2. The High Cost of Operating Pilgrim 



A. Boston Edison projections 



In May, 1987, Boston Edison 
developed projections of Pilgrim's future 
costs in response to a request by the Mas- 
sachusetts Executive Office of Energy 
Resources (EOER). Edison's projections 
were also sent to the Office of the Attor- 
ney General, the Department of Public 
Utilities, and upon request, to 
MASSPIRG. 



BECO projects that the cost of 
electricity from the Pilgrim plant will in- 

Flgure 4 

PILGRIM COST COMPONENTS 



crease from 6.53 cents per kilowatt 
hour (Kwh) in 1988 to 16.76 cents per 
Kwli in 2012 (Figure 4), primarily as 
the result of inflation. Another way of 
looking at the cost of Pilgrim is to add 
up the total bill to ratepayers for the 
plant's costs over the remainder of its 
expected life. The "present value" of 
BECO's estimate of future Pilgrim 
costs (discounting future dollars at the 
10.55 nercenf annual rate Edison uses 
to account for the declining value of 
money over time) is $3.3 billion in 1987 
dollars. 



BECO Assumptions ~ $ per Kwh 




(See next page for explanation.) 



291 



HOW Pttgrim Costs Are Calculated ! 

The grsph on the opposite p^e sbov/s how much Boston Edisoa expects to charge its cuslomeis each 
year for ctectridty from Rlgripi, based on the standard ruks of utility regulation. Electric companies ■ 
wrc allowed to recover most operating and fuel expenses directly in rates as they are incurred each 
year. Utility investment in ms^or plant and equiproeni is recovered over the operating life of the plant ; 
tiiroi^ depredation charges. Utilities arc aUo allowed to charge customers for their financing costs, • 
bdttdEiiig a profit on their iitvesimetH. 

Tttebottamsectiooof each bar isi the graph shows the financing charges, or {sbim, that BECO ex- 
pects to earn on. its PUgrnB investiaBiit. The return consists of interest payments on debt borrowed to 
finaBce ^I^ib, and the profits BECO expects regulators to allow it to earn on its iDvestnrent in the 
plant Ute neM area up represents d6prf^:iatif)n of BECX)'s Pllgrtm investment. The third area from 
thoboUotttdcpicts nperation a nd nminh Miance (0&M> charges, which include labor and direct 
i^perptia^ ei^nscs. Above O&M are the costs for nuclear £ueI, inchiding current estimates of waste 
(Ssposal wste- The next area of the graph shows how much money is collected to pay for dscijinnui: . 
jjflniag the plant at the end of its operating life. The top area indicates mwcftllanenns expenses, such 
as lnsow»c<^ and local property taxes, , 

BECO expects to cam a 14:4 perceai rate orreitun on its PHgrirt mvestmeni. About 38 percent of 
tbat ammmf is paid to th« federal government for income taxes. Every billion dollars invested in 
Pflgtimtfaus translates into ^44 million in charges per year in rates. Each year, 1/40 of the investment 
in l4]gtkD.is^ charged to ratepayers for depreciation, and that amount is subtracted trom the next 
year's 'rate base,* an account In the ntifity's books representing the amount of investment on which 
the nlility can earn a return. . The current fise for waste disposal assessed by the Etepartment of Ener- 
gy is one-tenth of a cent per KWh. Decommissiomng cost charges are calcnlatsd to accumulate the 
$325 nuBiOR (in 1^6 doQar^ Edison estimates will be necessary to dismantle the nudear plant b the 
year 2^112. Property taxes average abont 1.8 percent of the %'Blue of the plant in rate base. Insuraitce 
costs incTBWc over time from $5-15 miUion a year. 

The cost per kilowan houi is i^dcidated by dividing the total annual cost by the number of Kwh 
generated per year. KWh j>er )%» t« afunction of capacity factor (see Chapter 3, Section B) multi- 
pMed by37£Q hoars per year tiates the 670,000 kilowau sixc of the plant, Edison assumes a 70 percent j 
capacity factor fot future Klgpm operation. i 



But based on historic iiucl^r cost 
trends, Edison is greatly underestimating 
Pilgrim costs. Projecting the total cost of 
electricity from a power plant involves 
making nimierous assumptions about 
various cost components, as well as the 
overall operating performance of the 
plant. Three assumptions irt particular 
dominate the final results: the rate of capi- 
tal additions, oi>eration and maintenance 
(O&M) expenses, and the amount of time 
the plant can be expected to operate 
(capacity factor). 



B. MASSPIRG projections 



MASSPIRG has compared Edison 
assumptions in each of these areas to 
actual performance and cost trends at 
Pilgrim and other nuclear plants 
around the country. The sf>ecific results 
of these comparisons are presented in 
Appendix B. In general, Edison projec- 
tions assume that the past performance 
of Pilgrim and other nuclear plants 
provide no guide to future costs Consi.'?- 
tent historical trends - both at Pilgrim 
and at nuclear plants around the 



292 



country — are assumed to immediately 
stop. 

O&M costs, which have increased na- 
tionally by 1 1.4 per year, after adjusting 
for inflation, and by 13.8 percent annually 
at Pilgrim, are projected to increase at 
only 0.5 percent per year henceforth. 
Capital additions, which have escalated 
nationally at 13 percent per year after in- 
flation, and much faster at Pilgrim, are 
also forecast by Edison to increase by 0.5 
percent per year in the future. Despite 
the fact that Pilgrim has had a lifetime 
capacity factor of only 50 percent, and the 
national average for nuclear plants is 60 
percent, Edison predicts that Pilgrim will 
average a 70 percent capacity factor in the 
future. 

Nuclear utilities around the country 
have been making similar assumptions for 
many years. Each year, the utilities 
project that nuclear costs will freeze at 
then-current levels. Instead, real costs 
have continued to rise. The basic forces 
that have run up nuclear costs in the past 
will continue to increase costs in the fu- 
ture. These factors include technical 
problems discovered as nuclear plants 
gain more operating experience, un- 



resolved generic nuclear safety issues, 
the aging of reactor parts, and the 
potential for both small and large 
nuclear accidents to create new 
regulatory requirements. (See Appen- 
dix C for additional discussion.) 

It is therefore important to examine 
more realistic assumptions for nuclear 
costs. MASSPIRG looks at three alter- 
native assumptions for each major 
nuclear cost component. In a "Pilgrim 
Historical Case," future costs are as- 
sumed to continue to escalate in line 
with historical trends for the Pilgrim 
plant. In a "National Trend Case," 
Pilgrim cost trends are predicted to im- 
orove to match those of the average 
plant having Pilgrim's characteristics. 
For a "Pilgrim Optimistic Case," it is as- 
sumed that future Pilgrim co.sts will im- 
prove to a level substantially better 
than would be expected based on either 
Pilgrim or national trends. 

The detailed basis of MASSPIRG's 
alternative projections are presented in 
Appendix B. Figures 5 and 6 Olustrate 
the effect of the revised assumptions on 
the aimual cost per Kwh and on the 
total present value of Pilgrim costs to 



Figure 5 
PILGRIM ANNUAL GENERATION COSTS 
Alternative Scenario Analysis 




BECO 



Opt ^ Nat^frend 



-2008—- 
Pila Trend 



293 




Figure 6 
RANGE OF PfLGRIM TOTAL COSTS 
Presen t Value (Billion 1987 $) 



0-^il^^ 



Trench 



?<fl 



k53 



— -Natiofrat Trer 



ratepayers, respectively. 

All three MASSPIRG cases share a 
number of extremely conservative assump- 
tions. In general, nuclear costs are as- 
sumed to be increasing according to 
linear trends (i.e.. a constant number of 
dollars per year, after adjusting for infla- 
tion) rather than according to exponential 
trends (i.e., a constant percentage in- 
crease per year, after inflation). The trend 
of increasing capital additions is still as- 
sumed to level off in a few years, despite 
evidence that it may actually be accelerat- 
ing. Plant performance is not assumed to 
deteriorate with age, despite evidence of 
declining capacity factors, particularly at 
salt-water-cooled plants like Pilgrim. 

For simplicity, and to be as favorable 
to Pilgrim as possible, this report also 
adopts a number of other Edison assump- 
tions which are biased in favor of Pilgrim. 
The Pilgrim plant is assumed to be 
operable until the year 2012 -- a total of 
40 years from when it entered service. 
The oldest commercial nuclear plant has 



^1 



^Opttmtsticr- 






Pilgrim 

operated for only 26 years, and 14 reac- 
tors have been retired atter less than 20 
years of operation. Pilgrim's operating 
license currently expires in the year 
2008. and would have to be extended 
by the NRC in order for the plant to 
operate until 2012. 

Real nuclear fuel costs are assumed to 
remain stable, even though ap- 
proximately half of the uranium used in 
domestic nuclear plants is imported, 
much of it from politically unstable 
countries such as South Africa.^^ 
BECO's estimates for nuclear waste dis- 
posal and for dismantling the radioac- 
tive plant are used, despite the fact that 
the necessary technologies have not yet 
been demonstrated and there is there- 
fore enormous uncertainty around es- 
timating these costs. And it is assumed 
that no serious nuclear accidents occur 
at Pilgrim or at any other U.S. nuclear 
plant. The conservative nature of these 
assumptions is discussed in more detail 
in Appendix C. 



294 



3. Economic Benefits of Retiring Pilgrim 



There are three categories of potential 
costs to ratepayers for retiring Pilgrim at 
this time. First, there is the cost of re- 
placement power. Second, there are costs 
to shut the plant down and decommission 
it, which must be paid whether the plant 
is retired now or later. Third, there is the 
potential cost of paying for past invest- 
ment in the plant. Each cost will be con- 
sidered separately. 

A. Replacement power 



The main cost of retiring Pilgrim would 
be to replace the electricity produced by 
the nuclear plant. As demonstrated in the 
recent New England Energy Policy Coun- 
cil study. Power to Spare, the least expen- 
sive means of obtaining new power 
supplies is to "mine" the electricity that is 
now wasted by inefficient lighting, ap- 
pliances, and other electrical equipment 
in our offices, factories and homes. 
Utilities around the United States have 
found that they can flnance efficiency im- 
provements for their customers at an 
average cost of less than two cents per 
Kwh. That is less expensive than opera- 
tion and maintenance costs alone at 
Pilgrim. A report to Boston Edison's 
Board of Directors in March, 1987, found 
that cost-effective efficiency improve- 
ments could reduce electric demand in 
Boston Edison's service territory by as 
much as 1,000 Mw over the next 15 

14 

years. 



Another readily available source of 
replacement power for Pilgrim would 
be the purchase, of electricity from new 
plants built and owned by independent 
small power producers, generally 
referred to as "Qualifying Facilities" or 
"QFs." Since the pas'.age of the federal 
Public Utility Regulator)' Policies Act 
(PURPA) of 1978, which required 
utilities to purchase power from inde- 
pendent producers at fair prices, there 
has been a rapid increase in the 
development of such facilities 
throughout the country. 

In January, 1987, in response to 
rules enacted by the Massachusetts 
Department of Public Utilities, Boston 
Edison sent a Request for Proposals to 
potential developers to supply 200 
megawatts (Mw) of Edison's power 
needs by 1992. The utility's projection 
of future oil costs was set as the ceiling 
price for acceptable offers. In June 
Edison received bids from 61 projects, 
representing a total of 1848 Mw. The 
number of proposals received was well 
above the utility's expectations. In fact, 
in its April 1987 forecast, the New 
England Power Pool h?d projected that 
only 1391 Mw of independent power 
would be avaibble for the ertire region 
by the year 2002. 

The majority of the proposals were 

for co3;r.';:ali:.; TacUtics - v.liioh 
produce useful heat and electricity in 
the same process - and other small 
power facilities using a variety of fuels 



295 



Figure 7 



BECO-8 RFP«1: TOTAI, MT^ BID BY FUEL TlTS 
iB»-.»2 u* -soy 61 ^to^tcrz 



Oth«r (1 S.eX)^/-''^ 


^^ Natural 


/ 


|^:'^-vvv' ;^ Ga« (31.'?;) 


Wood * Peat (3.4J!) ^S;>-^,^ ■ 




^^^^^^^^^^ 


■i^:.-^', .>^'%i.^ 


^^^^^^^5= 


=^:i;i- ;.^^•-^v>3 


R«tuae (10. BX) i&r^^^^ 


T^-^^f 


"^ir iH.iii;;'"' 


-: ^- Wnd (O.St) 




/' 


X;'!^''' 


,,:,. • v/ 




Coal (35.3X) 



(Figure 7). Over 240 Mw would be 
produced using renewable energy sour- 
ces, such as biomass, wind or hydropower. 

Some of the projects, particularly the 
200 Mw of plants which would bum 
refuse as fuel, may present emaronmental 
problems. MASSPIRG does not neces- 
sarily endorse all of the proposed QFs. 
However, the combination of energy ef- 
ficiency improvements and the large num- 
ber of small power and cogeneration 
projects provides a more than adequate 
pool of potential replacement power for 
Pilgrim. The combined potential of ener- 
gy efficiency improvements and inde- 
pendent power projects exceeds Edison's 
share of the Pilgrim plant and its 



forecast of power needed to meet in- 
creased demand through the year 2012 
by over 1,100 Mw.^^ 

Nine QF projects, representing 350 
Mw, were selected by Edison as an ini- 
tial "Award Group" for final contract 
negotiation. The average Award Group 
bid was sig:niricantly below the price of 
Pilgrim-generated electricity, even 
using all of Boston Edison's Pilgrim 
cost assumptions (Figure 8). 

If Pilgrim were lo be replaced, there 
v'ould be a second round of bidding. It 
is quite likely that many bids would be 
lowered given the large, and previously 
unknown, surplus of potential supply 
o^er ^oiouii's demand. In the first 
round, potential developers were bid- 
ding primarily against BECO's extreme- 
ly high projection of oil price increases. 
The utility forecasts oil prices to in- 
crease at an average rate of over ten 
percent a year, approximately five per- 
cent above the assumed inflation rate 
between now and the year 2012. Oil 
prices would increase from their cur- 
rent $20 per barrel to $166 per barrel 
in 2012, or to over $53 a barrel in 1987 
dollars adjusted for inflation. 



Figure 8 
PILGRIIVI VS. QF ANNUAL GENERATION COSTS 
BECO Projection - $ per Kwti 




18^ 
8:8? 

0.00 



2123 



Pilgrim 



Year 



Award Group 



296 



To be as favorable to Pilgrim as pos- 
sible, however, the Award Group bids are 
assumed by MASSPIRG to represent the 
low end of a range of replacement power 
costs. Efficiency savings are assumed to 
be used entirely to displace demand 
growth rather than to replace Pilgrim. 
The average bid of the next block of 740 
Mw is used as a middle estimate of 
Pilgrim replacement costs. And the 
average bid of all the non- Award Group 
projects is adopted as a high estimate of 
replacement power costs. 

Using BECO's assumption of a 70 per- 
cent capacity factor for Pilgrim, the total 
present value of replacement power 
needed would range from $2.5 billion, 
based on the Award Group, to $2.9 bil- 
lion, based on the average non-Award 
Group bid, through the year 2012 (Figure 
9). If one assumes lower Pilgrim capacitv' 
factors, replacement power would cost 
even less. 

All the proposed QFs have projected 
in-service dates before 1992, with 400 Mw 
expected to be available by the end of 
1990. For this study, it is assumed that all 
QFs begin operation in 1992. Until that 
time, replacement power costs are as- 
sumed to equal energy costs from reserve 
oil-fired plants, plus an additional charge 
by the New England Power Pool for 
providing reserve capacity. The 1987 New 
England Power Pool forecast shows a 
more than adequate reserve margin of 
generating capacity through 1992 ~ even 
if the Pilgrim, Seabrook, and Maine 
Yankee plants are not in service. 

Reliance on non-utility power plants 
poses certain obvious risks to a utility, 
since it will not control the construction 
or operation of the QF plants. These risks 
must be weighed against risks associated 
with Pilgrim, however. Pilgrim could be 
closed by federal regulators because of an 



accident at another nuclear plant, as 
well as by incidents at the plant iiself. 
The diversity of the QF projects makes 
it more likely that a given amount of 
power vn\] be available at all times 

The QF contracts also provide in- 
sulation from important financial risks, 
since they are based on payment per 
Kwh produced. Their private owners 
thus assume the risks of cost overruns, 
poor plant performance and 
profitability. Most of the Award Group 
contracts are tied to the Consumer 
Price Index, thereby requiring utility 
customers to bear only ihe risk of unan- 

Figure 9 

PILGRIM VS RhPU\oEMENT POWER COSTS 



BECO Assumptions - Billion $ 




Pilgrim 



gj, Replacement power 



ticipated general inflation. With 
Pilgrim, however, ratepayers are ex- 
pected to bear the risk of all cost in- 
creases, including inflation, as well as 
the risk that the plant does not perform 
as reliably as expected. 

B. Other shutdown costs 



A decision to retire Pilgrim at this 
time would involve some costs in addi- 
tion to replacement power. Decommis- 
sioning costs, for instance, would stil! 
have to be incurred whenever Pilgrim 



10 



297 



is retired. Actually, since the cost of 
decommissioning is likely to increase as 
the plant becomes more radioactive, it 
would almost certainly be cheaper to 
decommission it earlier. To be conserva- 
tive, however, these potential savings are 
not considered here. Costs that would 
clearly have to be incurred to shut Pilgrim 
down must be added to the cost of re- 
placement pwjwer (or subtracted from the 
cost of Pilgrim) to evaluate the economics 
of early retirement of the plant. 

In addition to direct decommissioning 
costs of $126 million in 1987 dollars, 
BECO estimates that closing Pilgrim will 
require additional operation and main- 
tenance costs over a five year decommis- 
sioning period. The total decommis- 
sioning and shutdown costs add $206 mil- 
lion, in addition to the cost of replace- 
ment power, to the present value cost of 
retiring Pilgrim. Edison fails to include 
these costs in its analysis of continuing to 
operate Pilgrim, however, presumably be- 
cause the costs would be iacurred after 
the year 2012 - the last year BECO looks 
at In the MASSPIRG scenarios, the 
present value of the post-operation costs 
are included in both early and late retire- 
ment scenarios. 

C. Sunk costs. 



Another potential cost to retiring 
Pilgrim is repayment of the money that 
Edison has invested in the plant to date ~ 
generally referred to as "sunk costs." 
POgrim sunk costs will total $846 million 
by the end of 1987. In its analyses of the 
cost of retiring Pilgrim, BECO effectively 
assumes that ratepayers would pay for 
the utility's entire investment in Pilgrim, 
along with the same rate of profit it 
would earn if the plant were operated 
(Figure 10). 



Figure 10 

PILGRIM OPERATION VS RETIREMENT 
4 BECO Assum ption s - Billion $ 





23 Pll ^ Rep.Pwr K2I Shutdwn ^ Sunk 

In addition to its investment in the 
plant itself, Edison also includes a $50 
million investment in an inventory of 
nuclear fuel and $20 million in 
materials and supplies in Pilgrim sunk 
costs. After the Pilgrim 2 unit was can- 
celed, however, BECO was able to 
recover 64 percent of its investment in 
nuclear fuel by selling it to other 
utilities.** In the MASSPIRG 
scenarios, therefore, it is also assumed 
that BECO will recover 64 percent of 
its current investment in fuel, materials 
and supplies through sales to other 
utilities. 

If Pilgrim were retired, it would ac- 
tually be up to the Department of 
Public Utihties (DPU) to determine 
who should pay for Pilgrim sunk costs. 
Under a policy adopted in a Western 
Massachusetts Electric Company case 
in 1984, the DPU ruled that sunk cost 
recovery would no longer be allowed 
for investments that were not "used and 
useful" to utility customers, such as 
plants that were canceled while still 
under construction. In a 1985 
decision on excess capacity, the Depart- 
ment modified its policy to allow 
utilities to recover uneconomic invest- 
ments over time, but without charging 



11 



298 



20 

ratepayers for financing charges. This 
policy, which is followed by most state 
utility commissions, results in a sharing of 
sunk costs between utility ratepayers and 
investors. Stockholders are also able to 
share their losses with the federal govern- 
ment, which allows generous tax deduc- 

21 

tions for investment losses. 



D. Alternative scenarios show 
savings from retiring Pilgrim. 



Three scenarios were constructed to 
cover the widest reasonable range of as- 
sumptions for the costs of operating or 
retiring Pilgrim. The Pilgrim Optimistic 
Case combines all the assumptions 



Table 1. ALTERNATIVE ASSUMPTIONS USED IN MASSPIRG PILGRIM J 

PROJECTIONS 

'Capacity Capital O&M Replacement 

Factor Additions Expenses Power 



Pil^m 
Tfistorical 
Trend Case 


Pil^im 
Historical 

50% 


Pilgriin 
Histoi ical 
to years 


Pilgrim 
Historical 


Averge of 
Aw'ard Group 
QFs 


Natiohaf 

Ttend 

Case 


National 
Trend 
Pilgrim to 4/86 

56% 


National 
Trend 
5 years 


liaiiuqal 
Treiid 


Average of 

Next 740 MW 
QFs 


Pilgrim 

Optimistic 

C«se 


National avg. 

aUBWRs 

63.2% 


Pilgrim 

Low Historical 

5 years 


2% Real 
Escalation 


Average of 

all 1327 KfW 

Unsigned QFs ; 


Boston 
Edison 


70% 


05% Real 
Escalation 


0.5% Real 
Escalation 


Awrage of 

all 132? MW 

Unsigied QFs j 



Table 2. ADDITIONAL CONSERVATISMS IN ALL SCENARIOS 



Jtudear^vastc 

disposal: No increases from current BECO assumptions 

^utdown: :;; No savings from early decommissioning 

(Opacity factor No declining effect from salt-water cooling 

Capital Additions: No increases after 5- 10 years 

BECO-assnmed decreases in last five years of operation 
No repeat of 1984 and 1987 major repairs 

O&Mand 

Capital AddUions: Linear rather than exponential trend increases 

Miscellaneous: "W-year lifetime 

No increases in nucleai insurancf 

No serious acc'dents 

No societal costs 

No nuclear subsidies included in Plgrim costs 



12 



299 




Figure 11 

PILGRIM OPERATION VS RETIREMENT 
Present Value (Billion 1987 $) 




^ 



h^ 



m 




^^^,^ Repl.Power 



most favorable to Pilgrim — the most op- 
timistic projections of Pilgrim costs, and 
the highest price for replacement power, 
equal to the average bids of all non- 
Award Group QFs. The National Trend 
Case assumes that Pilgrim costs improve 
to the level predicted by the national 
trend for a plant with Pilgrim's charac- 
teristics. A middle estimate of replace- 
ment power is used, equal to the price of 
the least expensive 740 Mw of QF bids 
after the Award Group. The Pilgrim His- 
torical Case assumes that all Pilgrim cost 
components follow the same trends they 
have in the past, and that replacement 
power could be obtained for the price of 
the Award Group bids from QFs. Table 1 



Shutdown 



Sunk 



summarizes the assumptions employed 
in each scenario. Table 2 hsu. the addi- 
tional assumptions favorable to Pilgrim 
that were made in all MASSPIRG 
scenarios. 

The alternative scenarios indicate 
that the present value of savings to 
ratepayers from retiring the plant 
would range from $46 million to $1.6 
billion over 25 years, even if ratepayers 
were to pay for all sunk costs (Table 3; 
Figure 11). The $1.6 billion savings is 
approximately equal to $540 for the 
average Edison residential customer. If 
investors were to pay sunk costs, the 
savings from retiring Pilgrim would in- 
crease to a range of $769 million to 



SAVINGS TO RATEPAVEJK FROM RETIRING PILGRIM 




Ratepayers Pay 
Sonk Costs 


Investors Piay 
Sunk C^ts 


Pilgrim Historical 
"trend Case 


S1.56 bUIion 


$2.28 billion 


Nsttlortal 
TmtdCase 


$813 million 


$1.54 billion 


Pi^m Qptinistic 
Case 


S49 million 


$773 million 


BECO • 

AjHHUBptiotU 


-$611 million 


$168niillJon 


13 



300 



$2.3 billion. Detailed annual costs for all 
scenarios are presented in Appendix A. 

Figure 12 illustrates how the present 
value of the cumulative savings from retir- 
ing Pilgrim changes over time in each 
scenario, assuming that ratepayers pay for 
the full sunk costs, including a profit on 
Pilgrim investment to date. The cumula- 
tive savings at any point in time is equal 
to the difference between total Pilgrim 
costs and the total costs of replacement 
power, shutdown and sunk costs to that 
time. 

Graphs of cumulative savings are espe- 
cially useful for looking at the effect of 
changing only one assumption at a time 
on the benefits of retiring Pilgrim. Figure 

Figure 12 

CUMULATIVE SAVINGS FROM 
Present Value (Billion 



13 illustrates the effect of changing 
only the assumption about how 
regulators might deal with Pilgrim sunk 
costs if the plant were retired. The mid- 
dle line represents the usual regulatory 
practice for plants canceled under con- 
struction, where ratepayers would 
repay all sunk costs over time but with 
the utility earning no profit on its sunk 
investment. In this case, it is assumed 
that Pilgrim sunk costs would be 
charged to ratepayers over the same 25 
year period as they would have been if 
the plant had operated. Under tradi- 
tional regulatory practice, ratepayers 
would save money, at least through the 
year 2008, by retiring Pilgrim, even if 
all BECO assumptions about the 
plant's future costs hold. 

RETIRING PILG. 
1987$) 




rfS^rend 



Pilg.Trend 



Figure 13 

CUMULATIVE SAVINGS FROM RETIRING PILG 
BECO Assumpt i ons Ex cep t Sunk Costs 




InvestorB pay 



Customers pay 



14 



301 



4. Conclusions and Recommendations 



Retiring Pilgrim would clearly save 
utility customers money, under a wide 
range of reasonable assumptions, even if 
ratepayers have to pay a full return on the 
sunk costs of the plant. The Pilgrim 
nuclear plant should therefore be im- 
mediately and permanently retired. 

While no state official or agency has 
the direct authority to order the shutdown 
or retirement of a nuclear plant, the Mas- 
sachusetts Department of Public Utilities 
(DPU) is responsible for determining 
what, if any, utility investments and expen- 
ses can be charged to ratepayers, under a 
broad statutory mandate to ensure just 
and reasonable electric rates. If it were to 
determine that ongoing investment in 
Pilgrim were imeconomical, the DPU 
could prohibit its owners from financing 
or charging ratepayers for future invest- 
ment in the plant. 

MASSPIRG therefore recommends 
that the DPU disallow recovery of any ad- 
ditional Pilgrim investment, including the 
$150 million in capital additions Boston 
Edison has budgeted to spend in 1987. A 
second round of bidding from potential 
power suppliers should be initiated, with 



reasonable assumptions about Pilgrim 
costs used to set a target for acceptable 
bids. Energy efficiency contractors, 
who could seU energy savings to the 
utility, should also be encouraged to 
compete with QFs in bidding to replace 
Pilgrim. 

A similar process for dealing with 
new power plant construction has 
recently been proposed to the DPU by 
the state Executive Office of Energy 
Resources. Decisions to continue in- 
vesting in plants that have already been 
in operation are no different from 
decisions to start new construction, or 
to complete partially built plants. In 
each case, the ongoing investment must 
be weighed against potential alterna- 
tives. New utility investment in power 
plants should be allowed only if it 
would be "used and useful" ~ necessary 
to provide rehable electric service and 
the most economical alternative. To 
the extent that the Pilgrim plant cannot 
meet that test — and this report finds 
that it carmot ~ the plant should be per- 
manently retired. 



15 



302 



APPENDIX A 

ANNUAL COSTS OF PILGRIM VS. ALTERNATIVES 
BECO ASSUMPTIONS 



Year 


:ap- 


IqUI 


Snn. 


OccvK- Net 


[)e- 


Na- 1 


■uel 


Avg. 


Re- 


In- 


De- 


n- 


.0- 


Oe- Fuel 


K<I1 


- PILSRW TOTAL 


— ;• 


.- IFs -; 




tal 


Plant 


De- 


ilated Plant 


(er- 


ter- 




Rate 


turn co«e 


3re- sur- cal 


■.m 




AnnualCost 


n- 


^ost 


Cost 




ftd- 


Year 


pre- 


Depre- 


fear- red 


lals 




Base 


on 


rax 


cia- 


)nce 


rax 


•is- 




Costs 


in 


cre- 


m 


in 


Vinuo 


di- 


End 


cia- 


cia- 


:nd 


Tax 








Rate 




tion 






sion- 








[:ents 


■en- 


Cents 


Cents 


lOi'. 




ions 




tion 


tion 












Base 










inj 








aer 


tal 


per 


per 












( 


in 11 


Uions 


o-f dollars ) 




















kHh 


(iBil.)knh 


KlUh 


m.l. 


ira? 


150 


846 


24 


176 


670 


-104 


20 


51 


542 


56 


27 


24 


5 


11 


4 


1 


97 


227 


5.5 


1 


0.0 


3.3 


.3« 


1988 


40 


886 


28 


204 


682 


-113 


21 


51 


421 


44 


30 


2B 


5 


11 


5 


27 


99 


268 


6.5 


92 


2.2 


3.5 


14; 


IW 


40 


926 


29 


233 


693 


-122 


22 


50 


623 


44 


30 


29 


5 


11 


5 


24 


107 


276 


6.7 


126 


3.1 


3.4 


Ni 


IW 


70 


996 


32 


265 


731 


-130 


23 


50 


440 


66 


31 


32 


5 


12 


5 


24 


120 


294 


7.2 


152 


3.7 


3.7 


152 


1991 


40 


1036 


34 


299 


737 


-138 


24 


50 


454 


6B 


32 


34 


6 


12 


5 


24 


125 


305 


7.4 


169 


4.1 


4.2 


174 


1992 


42 


1078 


36 


335 


743 


-143 


24 


50 


655 


48 


32 


36 


4 


12 


6 


24 


131 


314 


7.4 


135 


4.5 


5.7 


232 


1997 


44 


1122 


38 


373 


749 


-147 


27 


54 


661 


48 


32 


36 


4 


12 


4 


24 


138 


326 


7.9 


202 


4.9 


4.1 


251 


1994 


46 


1168 


41 


414 


754 


-146 


28 


56 


670 


49 


33 


41 


6 


12 


7 


27 


145 


339 


6.3 


24',' 


5.8 


4.6 


272 


1995 


49 


1217 


43 


457 


760 


-143 


30 


60 


683 


71 


33 


43 


7 


12 


7 


29 


152 


353 


8.4 


258 


6.3 


7.2 


29» 


1996 


51 


1268 


46 


503 


765 


-139 


31 


66 


697 


72 


34 


44 


7 


13 


7 


31 


140 


370 


9.0 


278 


6.8 


7.8 


32'J 


1997 


54 


1322 


49 


553 


769 


-136 


33 


67 


706 


73 


35 


49 


7 


12 


8 


32 


148 


384 


9.3 


294 


7.2 


8.5 


349 


1998 


5b 


1J78 


53 


606 


772 


-133 


34 


75 


721 


74 


35 


53 


6 


12 


8 


34 


174 


403 


9.8 


316 


7.7 


9.2 


378 


1999 


59 


14J7 


57 


663 


774 


-129 


36 


75 


726 


75 


36 


57 


8 


12 


9 


34 


185 


41B 


10.2 


334 


8.1 


10.2 


42': 


2000 


62 


1499 


62 


725 


774 


-126 


38 


84 


739 


76 


34 


42 


9 


13 


9 


40 


194 


439 


10.7 


358 


8.7 


11.1 


45' 


2001 


65 


1564 


67 


792 


772 


-121 


40 


84 


742 


77 


34 


47 


9 


13 


10 


40 


204 


455 


11.1 


377 


9.2 


12.0 


491 


2002 


68 


1633 


73 


366 


767 


-115 


42 


92 


752 


78 


37 


73 


9 


12 


11 


44 


214 


478 


11.6 


402 


9.8 


13.2 


54 


200J 


72 


1705 


80 


946 


759 


-105 


44 


94 


755 


78 


37 


80 


10 


12 


11 


45 


225 


498 


12.1 


425 


10.3 


13.9 


573 


2'M 


75 


1780 


88 


1035 


746 


-93 


46 


99 


760 


79 


37 


88 


10 


12 


12 


47 


234 


522 


12.7 


451 


11.0 


15.1 


421 


2005 


79 


1859 


98 


1133 


727 


-78 


48 


105 


742 


79 


37 


98 


11 


11 


13 


50 


248 


547 


13.3 


476 


11.6 


16.5 


bV 


2004 


83 


1942 


110 


1242 


700 


-60 


51 


111 


741 


79 


37 


110 


11 


11 


14 


53 


240 


575 


14.0 


508 


12.4 


17.8 


729 


2007 


87 


2030 


124 


1366 


663 


-37 


53 


118 


754 


78 


37 


124 


12 


11 


15 


54 


273 


605 


14.7 


540 


13.2 


16.6 


765 


2008 


70 


2100 


140 


1506 


594 


-9 


43 


125 


718 


74 


35 


140 


13 


9 


14 


59 


287 


633 


15.4 


570 


13.9 


19.9 


819 


20O9 


56 


2156 


155 


1661 


494 


26 


34 


94 


619 


64 


30 


155 


13 


8 


17 


43 


301 


652 


15,9 


591 


14.4 


21.2 


970 


2010 


45 


2200 


172 


1834 


367 


66 


27 


62 


500 


52 


24 


172 


14 


6 


19 


67 


314 


449 


16.3 


610 


14.8 


22.5 


922 


2011 


36 


2236 


192 


2026 


210 


MS 


22 


31 


341 


37 


18 


192 


15 


3 


21 


71 


332 


488 


16.7 


629 


15.3 


23.6 


979 


2012 


29 


2265 


239 


2265 








17 





3 








239 


15 





11 


75 


348 


488 


16.8 


645 


15.7 


25,3 


1038 


2013 


































139 














20M 


































70 














2015 


































70 














201& 


































70 














2017 


































70 














2018 


































70 














Total 
















































Present 












































1 


• 


Value 




































3287 




2302 






2913 



16 



303 



ANNUAL COSrS OF PILGRIM VS. ALTERNATIVES 



OPTIMISTIC CASE 



Ve.i- 


>- 


Total 


Ann. 


ftccuii- Net 


De- 


Ma- 


■uel 


Avj. 


Re- 


In- 


De- 


n- 


.0- 


De- 


■uel 


OW 


- PILBRIN TOTAL 


— > 


: <- UFs -;- 




tal 


Plant De- 


jiated Plant 


fer- 


ter- 




Rate 


turn co«e 


ore- sur- cal 


:m 




flnnualCcret 


In- 


Cost 


Cost 






M- 


Veap 


pre- 


Bepre- 


If ear- 


red 


ials 




Base 


on 


rax 


ela- 


uice 


Tax 


ms- 






kists 


in 


cre- 


in 


1 in i^nus 




ji- 


End 


cia- 


::a- 


End 


Tax 








Rate 




tion 






sion- 








Cents 


■en- 


Cents 


, Cents 


as'. 




lons 




tion 


tion 












Base 










ing 








per 


tal 


per 


per 












( 


in 11 


Uions 


0* 


Jollars ) 




















kwh 


(■il.) 


kNh 


; kHh 


B\\. 


ive7 


150 


846 


24 


176 


670 


-104 


20 


51 


562 


58 


27 


24 


5 


U 


4 


1 


97 


226 


6.1 


B 


0.2 


1 3.3 


3( 


1988 


45 


891 


28 


204 


687 


-113 


21 


51 


624 


64 


30 


28 


5 


11 


5 


24 


99 


266 


7.2 


98 


2.7 


1 3.5 


13i 


1989 


50 


941 


30 


234 


707 


-122 


22 


50 


633 


65 


31 


3(1 


5 


11 


5 


21 


107 


275 


7.4 


134 


3.6 


; 3.6 


13, 


1990 


70 


1011 


32 


266 


745 


-130 


23 


50 


653 


67 


32 


32 


5 


12 


5 


21 


120 


295 


7.° 


160 


4.3 


• J. 7 


i:t 


1991 


60 


1071 


35 


301 


770 


-139 


24 


50 


675 


70 


33 


35 


6 


12 


5 


21 


125 


308 


8.3 


179 


4.8 


: 4.2 


157 


1992 


66 


1137 


38 


339 


798 


-145 


26 


50 


695 


n 


34 


38 


6 


13 


6 


21 


131 


321 


8.6 


199 


5.4 


; 5.7 


2K 


1995 


69 


1206 


42 


381 


825 


-150 


27 


54 


722 


75 


35 


42 


6 


13 


6 


23 


138 


338 


9.1 


220 


5.9 


; 6.1 


2. 


1994 


73 


1279 


45 


426 


853 


-150 


28 


56 


751 


78 


37 


45 


6 


14 


7 


24 


145 


355 


9.6 


263 


7..1 


. 6.6 


2f> 


1995 


76 


1356 


49 


476 


880 


-148 


30 


60 


783 


81 


38 


49 


7 


14 


7 


26 


152 


374 


10.1 


285 


7.7 


, 7.2 


266 


1996 


80 


1436 


54 


530 


906 


-147 


31 


66 


816 


84 


40 


54 


7 


15 


7 


28 


161 


396 


10.7 


7,'ii 


B.« 


: '.8 


289 


1997 


84 


1520 


59 


589 


931 


-145 


33 


67 


843 


87 


41 


59 


7 


15 


8 


29 


172 


418 


li.3 


334 


9.' 


; 8.5 


:ii 


1998 


89 


1609 


65 


654 


954 


-144 


34 


75 


876 


91 


43 


65 


8 


15 


8 


32 


183 


445 


12.0 


564 


9.8 


i 9.2 


•Al 


1999 


93 


1702 


71 


726 


976 


-142 


36 


75 


899 


93 


44 


71 


8 


15 


9 


32 


195 


468 


12.6 


390 


10.5 


1 10.2 


^1 1 


:»oo 


98 


1799 


79 


805 


995 


-139 


38 


84 


929 


94 


45 


79 


9 


16 


9 


36 


206 


498 


13.4 


422 


11.4 


: u.i 


412 


2001 


102 


1902 


87 


892 


1010 


-136 


40 


84 


947 


98 


46 


87 


9 


16 


10 


36 


222 


524 


14.1 


451 


12.2 


: 12.0 


4*3 


2002 


108 


2009 


97 


988 


1021 


-130 


42 


92 


971 


100 


47 


97 


9 


16 


11 


40 


256 


556 


15.0 


485 


13.1 


; 13.2 


498 


2003 


113 


2122 


108 


1096 


1026 


-120 


44 


94 


987 


102 


48 


108 


10 


16 


11 


40 


251 


586 


15.8 


517 


14.0' 


; 13.9 


517 


2004 


119 


2241 


121 


1217 


1024 


-108 


46 


99 


1002 


104 


49 


121 


10 


16 


12 


45 


267 


622 


16.8 


555 


15.0 


; 15.1 


So. 


2005 


125 


2366 


136 


1353 


1013 


-91 


48 


105 


1013 


105 


50 


136 


11 


15 


13 


45 


284 


659 


17.8 


593 


16.0 


■ 16.5 


611 


2004 


131 


2496 


154 


1507 


990 


-68 


51 


111 


1018 


105 


50 


154 


11 


15 


14 


48 


503 


700 


18.9 


657 


17.2 


1 17.8 


6" 


»07 


137 


2634 


176 


1683 


951 


-39 


53 


118 


1014 


105 


50 


176 


12 


14 


15 


51 


522 


745 


20.1 


685 


18.4 


1 18.0 


6'71 


2008 


110 


2744 


201 


1884 


859 


-2 


43 


125 


970 


100 


47 


201 


13 


13 


16 


54 


543 


786 


21.2 


726 


19.6 


1 19.9 


'41 


2009 


88 


2831 


226 


2110 


721 


44 


34 


94 


849 


88 


42 


226 


13 


11 


17 


57 


365 


818 


22.1 


760 


20.5 


; 21.2 


786 


2010 


70 


2902 


252 


2362 


540 


101 


27 


62 


695 


72 


34 


252 


14 


8 


19 


60 


389 


848 


22.9 


790 


21.3 


: 22.5 


833 


2011 


56 


2956 


284 


2646 


312 


171 


22 


31 


506 


53 


25 


284 


15 


5 


21 


64 


414 


879 


23.7 


822 


22.2 


: 25. s 


89: 


2012 


45 


3003 


357 


3003 





263 


17 





257 


27 


13 


557 


15 





U 


68 


440 


930 


25.1 


886 


23.9 


; 25.3 


93 


2013 


































176 














2014 


































88 














2015 


































88 














2016 


































88 














2017 


































B8 














20iB 


































88 














lo^al 
















































Present 
ValLe 




































3408 




2679 




1 


262^ 



17 



304 



ANNUAL COSTS OF PILGRIM VS. ALTERNATIVES 
NATIONAL TREND CASE 



Zif- Total tnn. Accii*- Net De- Na- Fuel flvg. Re- In- De- In- Lo- De- Fuel 0M1 



lUl Plant De- ulated Plant fer- 

Ad- Year pre- Depre- Year- red 

di- End cia- cia- End Tax 

tions tion t\ot\ 



ter- Rate tum co«e pre- sur- cal coa 

lals Base on Tax cia- ance Tax iis- 

Rate tion sion- 

Base inj 



iva? 

1988 
1987 
1990 
1991 
1992 
1993 
1994 
1995 
1996 
1997 
1998 
1999 
2000 
2001 
2002 
2003 
2004 
2005 
2006 
2007 
2006 
2009 
2010 
2011 
2012 
2013 
2014 
2015 
2016 
2017 
2018 



150 
62 
68 



846 
908 
976 



75 1051 

82 1133 

90 1223 

94 1318 

99 1417 

104 1521 

109 1630 

115 1745 

121 1865 

127 1992 



24 
28 
31 
34 
37 
42 
46 
51 
57 
63 
70 
78 
87 

133 2125 97 
139 2264 108 
146 2411 121 
154 2564 136 
161 2726 154 
170 2896 174 
178 3074 199 
187 3261 230 
150 3410 263 
120 3530 297 
96 3625 333 
77 3702 376 
61 3763 475 



( 

176 
204 
235 
269 
306 
348 
394 
445 



in (illicms of dollars ) 



670 

704 

741 

782 

827 

875 

923 

971 

502 1019 

565 1065 

635 1109 

713 1152 

800 1192 

897 1228 

1005 1259 

1126 1284 

1262 1302 

1416 1310 

1590 1305 

1790 1284 

2019 1241 

2282 1128 

2579 950 



2912 
3288 
3763 



713 

414 





-104 20 

-113 21 

-123 22 

-132 23 

-141 24 

-148 26 

-155 27 

-156 28 

-157 30 

-157 31 

-157 33 

-157 34 

-157 36 

-156 38 

-154 40 

-149 42 

-139 44 

-125 46 

-106 48 

-80 51 

-44 53 



2 
61 



135 27 
227 22 
346 17 



51 562 
51 632 
50 657 
50 686 
50 719 
50 758 
54 803 
56 850 
60 900 

66 951 

67 995 
75 1044 
75 1083 112 
84 1127 117 
84 1159 120 
92 1196 124 
94 1224 126 
99 1249 129 

105 1267 131 
111 1277 132 
118 1275 132 
125 1223 126 

94 1080 112 

62 890 

31 655 
333 



58 
65 
68 
71 
74 
78 
83 
88 
93 
98 
103 
108 



92 
68 
54 



27 
31 
32 
34 
35 
37 
39 
42 
44 
46 
49 
51 
53 
55 



24 
28 
31 
34 
37 
42 
46 
51 
57 
63 
70 
78 
87 
97 



57 108 

58 121 

60 136 

61 154 

62 174 
62 199 
62 230 
60 263 
53 297 
44 333 
32 376 
16 475 



11 
11 
12 
12 
13 
14 
H 
15 
16 
17 
17 
8 18 

8 IB 

9 19 
9 20 
9 19 

10 20 

10 20 

11 19 



11 
12 
13 
13 
14 
15 
15 



9 
9 
10 
11 
11 
12 
13 
14 
15 
16 
17 
19 
21 
11 



PILGRIM TOTAL -> 

AnnualCost In- Cost 

Costs in ere- in 

Cents aen- Cents 

per tal per 

I^Nh (•il.lkNti 



1 

r 



97 
99 



19 107 

19 120 

19 125 

19 131 



138 
145 



23 152 

25 161 

26 174 
29 188 
29 204 
32 219 
32 236 

35 254 

36 272 
38 292 
40 313 
42 336 
45 359 
47 385 
50 411 
53 440 
56 470 
60 501 

201 
100 
100 
100 
100 
lOO 



226 
265 
278 
299 
315 
332 
353 
375 
398 
425 
454 
488 
519 
557 
591 
631 
671 
716 
763 
816 
873 
926 
967 
1004 
1043 
1113 



6.9 
8.1 
8.5 
9.1 
9.6 
10.1 
10.8 
11.4 
12.1 
12.9 
13.8 
14.8 
15.8 
16.9 
18.0 
19.2 
20.4 
21.8 
23.2 
24.8 
26.5 
28.2 
29.4 
».6 
31.7 
33.9 



97 
137 
165 
187 
210 
236 
283 
309 
339 
370 
407 
441 
481 
518 
560 
602 
649 
698 
753 
811 
866 
909 
947 
986 
1069 



0.2 

3.0 

4.2 

5.0 

5.7 

6.4 

7.2 

8.6 

9.4 

10.3 

11.3 

12.4 

13.4 

14.6 

15.8 

17.0 

18.3 

19.8 

21.2 

22.9 

24.7 

26.3 

27.6 

28.8 

30.0 

32.5 



- QFs -:■ 
Cost 

in Annua' 
Cents Cost 

KMh Inil.- 



3.4 

3.6 

3.6 

^.2 

5.7 

4.1 

6.5 

7.0 

7.5 

8.2 

8.7 

9.6 

10.3 

11.0 

12.0 

12.7 

13.6 

14.7 

15.8 

16.5 

17.6 

18.6 

19.7 

20.9 

22.2 



27 
113 
117 
119 
136 
186 
200 
215 
230 
248 
268 
288 
314 
340 
362 
394 
417 
448 
484 
519 
541 
578 
612 
648 
688 
731 



I'otal 

'resent 

aiue 



3928 



2998 



2185 



18 



305 



AWIUAL COSTS OF 'ILGRIM VS. ALTERNATIVES 
PILGRIM TREND CASE 





ZAf- 


Total Ann. 


taujr Net 


De- Ha- Fuel flvg. 


Re- 


n- 


te- 


n- Lo- 


3e- Fuel Otfl < 


- PILGRIM TOTAL 


— > 


<~ QF-s 






itii 


Plant De- 


jlated Plant 


Fer- ter- 


Rate turn coae 


jre- sur- cal co« 




AnnualCost 


n- 


:ost I 


Cost 






M- 


Vear 


pre- 


Depre- 


Year- red lals 


Base 


un 


Fax 


:ia- ance 


Fax 


nis- 




Costs 


in 


: re- 


in 


in t^ifi' ■-■-. 




ii- 


End 


:ia- 


:ia- 


End 


Fax 




Rate 




tion 




sion- 








:ent5 


ci- 


:ents . 


Cents C 


ys- 




tions 




tion 


tion 








Base 










ins 








per 


tal 


per 


per 












( 


in «i 


lions of dollars ) 




















kNh 


■il.lkHh 


i-.iit ■■ 


ITiJ . ■' 


-07 


1^0 


844 


24 


174 


470 


-104 20 


51 542 


58 


27 


24 


5 


11 


4 


1 


97 


226 


7.7 


8 


0.3 


3.3 




'ce 


66 


912 


28 


205 


708 


-113 21 


51 434 


45 


31 


22 


5 


11 


5 


19 


99 


263 


9.0 


95 


3.3 


3.3 


1^ 


>B9 


73 


985 


31 


234 


750 


-123 22 


50 463 


69 


32 


31 


5 


12 


S 


17 


107 


277 


9.4 


136 


4.6 


3.5 


10- 


•?o 


80 


104i 


34 


270 


794 


-132 23 


50 497 


72 


34 


34 


5 


13 


5 


17 


120 


300 


10.2 


165 


5.6 


".4 


10- 


■V! 


88 


1154 


38 


308 


844 


-142 24 


50 734 


76 


36 


38 


6 


13 


5 


17 


125 


314 


10.8 


188 


6.4 


4.0 


lia 


■h'i 


97 


1251 


43 


351 


900 


-149 26 


50 778 


80 


38 


43 


6 


14 


6 


17 


131 


335 


11.4 


213 


7.2 


5.7 


16 


I'S 


m 


1354 


48 


398 


958 


-154 27 


54 830 


84 


41 


48 


b 


15 


6 


18 


133 


357 


12.2 


240 


3.2 


6.0 


ir 


;.« 


116 


1472 


53 


452 


1020 


-159 28 


54 888 


92 


43 


53 


6 


16 


7 


19 


146 


382 


13.0 


29f: 


9.9 


6.4 


'9' 


;?5 


126 


1598 


40 


512 


1064 


-140 30 


40 953 


9V 


47 


60 


7 


17 


7 


20 


159 


415 


14.2 


326 


11.1 


6.8 


199 


■' c 


133 


1734 


48 


580 


1154 


-141 31 


44 1024 


106 


50 


68 


7 


18 


7 


22 


173 


452 


15.4 


364 


12.5 


7 "^ 


2;i 


"17 


150 


1884 


77 


457 


1229 


-142 33 


47 1092 


113 


53 


77 


7 


19 


8 


23 


139 


489 


16.7 


405 


13.3 


7.4 


T?" 


■/2 


157 


2043 


87 


744 


1299 


-144 34 


75 1147 


121 


57 


87 


8 


20 


8 


24 


205 


532 


18.1 


451 


15.4 


8.0 


2.i 


>'.'! 


lis 


2209 


99 


843 


1344 


-145 34 


75 1230 


127 


60 


99 


8 


21 


9 


26 


223 


572 


19.5 


494 


16.8 


3.5 


2"' 


■'.■(' 


174 


2382 


112 


954 


1428 


-165 38 


84 1298 


134 


63 


112 


9 


22 


9 


29 


241 


419 


21.1 


543 


18.5 


9.1 


:>■ 


';■:'( 


182 


2545 


127 


1081 


1484 


-144 40 


84 1352 


140 


66 


127 


9 


23 


10 


29 


260 


463 


22.4 


590 


20.1 


9.5 


7H:. 


'02 


191 


2754 


144 


1225 


1532 


-140 42 


92 1410 


146 


69 


144 


9 


23 


11 


31 


280 


713 


24.3 


642 


21.9 


10.1 


y<' 


IT 


201 


2957 


163 


1388 


1569 


-150 44 


94 1457 


151 


71 


143 


10 


23 


11 


32 


302 


763 


26.0 


695 


23.7 


• 10.7 


.!■. 


iM 


211 


3148 


184 


1574 


1594 


-135 46 


99 1499 


155 


73 


134 


10 


24 


12 


34 


325 


819 


27.9 


753 


25.6 


11.3 


3;. 


0''!: 


222 


3390 


213 


1787 


1403 


-113 48 


105 1532 


158 


75 


213 


11 


23 


13 


36 


349 


878 


29.9 


313 


27.7 


' 12.0 


3^? 


' J 


233 


3423 


244 


2033 


1590 


-83 51 


111 1553 


161 


76 


244 


11 


23 


14 


38 


375 


944 


32.2 


381 


30.0 


12.7 


'7 


OC/ 


244 


3847 


285 


2318 


1549 


-41 53 


118 1557 


161 


76 


285 


12 


22 


15 


40 


403 


1014 


34.6 


952 


32.5 


; 13.1 


3€; 


3 


195 


4042 


329 


2447 


1415 


15 43 


125 1500 


155 


73 


329 


13 


19 


16 


42 


432 


1080 


36.8 


1020 


34.8 


!3.9 


v- 


'■'? 


156 


4219 


373 


3021 


1198 


88 34 


94 1335 


138 


45 


373 


13 


17 


17 


45 


463 


1133 


38.4 


1074 


36.6 


1 14.6 


427 


-\-J 


125 


4344 


420 


3441 


903 


178 27 


42 1108 


US 


54 


420 


14 


13 


19 


48 


496 


1179 


40.2 


1121 


38.2 


15.5 


'IS- 


■■'■ 1 


100 


4444 


474 


3917 


527 


292 22 


31 822 


85 


40 


474 


15 


7 


21 


50 


531 


1226 


41.8 


1169 


39.8 


! 14.5 


4, 


O.'-i 


80 


4524 


407 


4524 





444 17 


421 


44 


21 


407 


15 





11 


54 


568 


1318 


44.9 


1274 


43.4 


17.5 


51' 


"■-5 






























227 














■lA 






























114 














■;5 






























114 














'^'.';; 






























114 














/7 






























114 














'.3 






























J14 















w;M:*t 



4236 



3306 



175 



306 



Notes to Appendix A 
Assumptions and Metiiods 



Capital Additions: 

BECQ: Escalation of approxiniately .5 percent per year, after adjusting for inflation, from about $30 mil- 
lion per year (1986 constant dollars). Declines by 23 percent a year over last five years of plant's life. 

Optimistjr. - Ljnear growth at $2.5 million per year for five years to approximately $50 nullion per year 
(1986 dollars), followed by same escalation and decline as BECO. Derived from Unear regression of 
Pilgrim historical experience between 1973 and 1976, treating the four years with expenditures significant- 
ly above the trend line as one-time expenditures which will not recur. 

National Trend : Linear growth at $3.2 million per year for five years to $69 million per year (1986 $), fol- 
lowed by same pattern as BECO. Derived from ESRG multi-variate regression equation applied to 
Pilgrim. 

Pil grim Trend : 

Linear growth at $3-5 million per year for 10 years to $92 million per year year (1986$), followed by same 
pattern as BECO. Derived from linear regression, excluding two largest outliers. 

Plant-in-Service Year End: 

Calculated as in BECO Exhibit 1. 

= Capital Additions + Prior Total Plant Year End 

Annual Depreciation: 

= (Half of Year's Capital Additions -I- Prior Year Net Plant) / Remaining Life 

Deferred Taxes: 

Calculated as in BECO Exhibit 2. 

Prior Year Accumulated Deferred Taxes + (Tax Rate x (Year's Tax Depreciation - Year's Book 
Depreciation)) 

Year's Tax Depreciation calculated as in BECO Exhibit 2 (150% Double Declining Balance). 

Materials & Supplies: 

From BECO Exhibit 1. 

Nuclear Fuel in Rate Base: 

From BECO Exhibit 1. 

Average Rate Base: 

Calculated as in BECO Exhibit 1. 

= Net plant Year End + Deferred Taxes ^- Materials & Supplies -t- Nuclear Fuel in Rate Base - Half of 
Year's Capital Additions 



Return on Rate Base: 

Calculated as in BECO Exhibit 1. 

= Average Rate Base x 10.338% 



20 



307 



Income Taxes: 

CaloJated as in BECO Exhibit 1. 

= Average Rate Base x 4J?9% 

Insurance 

From BECO Exhibit 1. 

Local Taxes 

Calculated as in BECO Exhibit 1. 

= Average Rate Base x 1S% 

Decommissioning contribution: 

From BECO Exhibit 1. 

Sinking fund to accumulate $126 million (1986$) by 2012. 

Fuel: 

Calculated from BECO Exhibit 1. 

BECO's annual fuel estimate adjusted by ratio of assumed capacity factor to BECO's assumed capacity 
factor of 70%. 

O&M Costs: 

BECQ: 0.5% per year from 1990 

Optimistic : 2% real growth from year when BECO projection crosses National Trend line. 

National Trp.nd : Same as BECO to 1990. Linear growth of $3.6 million per year thereafter (1986$); 
derived from ESRG equation applied to Pilgrim characteristics. 

Pcfisimistic; 

Same as BECO to 1990. Then linear growth of $4.4 milUon per year (1986$) per year derived from linear 

regression of Pilgrim historical O&M costs from 1973 to 1986. 

Present value of O&M shutdown costs is included in present value of year 2012 O&M. Year 2013 O&M is 
assumed to be 40% of prior year; 20% for the five years thereafter. Based on BECO Exhibit 2. 

Annual Costs: 

= Return + Income Tax + Depreciation + Insurance + Local Tax + Decommissioning + Fuel + 
O&M 

Costs in Cents per Kwh: 

= Annual Cost / Aimual Generation 

Annual Generation = Capacity [670000 Kw] x 8760 hours/yr. x Capacity Factor 

Capacity Factor: 

EECQ:70% 

OptimUtir- 

Average of seven BWRs between 400 - 799 Mw for 1977-1986 

= 63.159% 



21 



\i 



308 



From North American Electric Reliability Coimcil, Equipment Availability Report 1975 - 1986 . 

National Trend : 

56 percent; derived from ESRG regression equation for Pilgrim and equal to Pilgrim's lifetime capacity 
factor before its shutdown in April, 1986. 

Pilgrim Trend: 

50 percent; Pilgrim's lifetime capacity factor as of October 1987. 

Incremental Costs: 

Incremental cost comparison is BECO's preferred way of comparing future Pilgrim costs with alterna- 
tives. Comparing Pilgrim incremental costs (which subtract shutdown and sunk cost charges from Pilgrim 
total costs) to alternative costs is the same as comparing Pilgrim lota! costs to alternative costs plus shut- 
down and sunk cost charges. 

As in BECO Exhibit 2 

= Anoual Cost - Cost of service on sunk costs 

Cost of service on sunk costs includes return and depreciation (amortization) on sunk costs as of end of 
1987 (846 million); plus O&M costs of $40 milLon in 1988 and $20 million per year in 1989-1993; plus in- 
surance of $2.3 million per year 1988-1993; plus property taxes declining from $9 million in 1988 to $1 mil- 
lion in 1993 and thereafter; plus decommissioning. In BECO Ca.<;e. S.SO million in nuclear fuel and $20 
million in materials and suppUes is included in sunk cost rate base. In MASSPIRG scenarios, it is assumed 
that 64% of the investment in fuel and supplies is sold to other utilities, and 36% included in rate base. 

Replacement Power Costs: 

Pilgrim Trend Case: 

= Average Award Group Bid; from John Whippen, Manager, Energy Resource Planning & Forecasting, 
Boston Edison, Letter to RFP Respondents, October 13, 1987. 

Natinna] Trend Case: 

= Estimated average bid from next 764 Mw supply block after Award Group. 

= RFP Ceiling Price - ((RFP Ceiling Price - Average Award Group Bid) 

x ((Average Supply Block Ratepayer Benefit Score - 1) / (Average Award Group Ratepayer Benefit Score 

-1))) 

The average Ratepayer Benefit Score of the Award Group was 1 Jl; the average Ratepayer Benefit Score 

of the next 764 Mw supply block was 1.22. Each year, the supply block price was assumed to capture 22/31 

of the benefits of the award group, or 70.9% of the difference between the ceiling price and the Award 

Group. 

RFP Ceiling Price from John Whippen, Letter to RFP Recipient, February 19, 1987. 
Ratepayer Benefit Scores from Frank McCall, Letter, October , 1987. 



= Estimated average bid of the entire 1327 Mw of acceptable QFs not in the Award Group. Calculated as 

above. Average savings = 52.4% of Award Group. 

Present Value: 

The calculation of present value of a future cash stream discounts future cash flows to reflect the time 

value of money. A dollar in hand today is worth more than a dollar next year, by the amount of interest 

that could be earned (or the interest payments that could be deferred) by having the dollar for the year's 

time. 

Discount rate = 10.55%, from BECO Exhibit 1. 



22 



309 



Appendix B 

MASSPIRG NUCLEAR COST ESTIMATES 



A. Capital additions 



Nuclear plants have required steadily 
increasing capital additions in order to 
replace worn-out parts and meet new 
safety standards. On average nuclear capi- 
tal additions have increased at 13 percent 
a year since 1970, after adjusting for infla- 
tion (Figure 14). Replacement of some 
reactor parts, such as cracked pipes in 
Boiling Water Reactors (BWRs) like 
Pilgrim, and steam generators in Pres- 
surized Water Reactors (PWRs), have re- 
quired as much as $100 million or more 
per plant. 

Pilgrim cost trends were analyzed by a 
statistical technique called "linear regres- 
sion analysis." An equation was deter- 
mined for the straight line that best fits 
Pilgrim's historical cost pattern, after ad- 
justing for the effects of inflation. To 



23 



measure national cost trends, this 
report uses equations developed by the 
Energy Systems Research Group 
(ESRG), a Boston- based consulting 
group that has studied nuclear costs for 
numerous state regulatory and con- 
sumer agencies around the country.' 
ESRG has analyzed nuclear cost trends 
using "multi-variate regression analysis" 
~ a technique which relates changes in 
nuclear costs to a number of factors 
such as plant type, size, location, 
vintage (in-sen'ice date), and year of 
operation. 

In general, plants with Pilgrim's 
characteristics have experienced far 
greater capital additions than the na- 
tional average. BWR capital additions 
have escalated faster than at PWRs, for 
instance, and salt-water cooled plants, 
like Pilgrim, have experienced more 
capital additions than fresh-water 



Figure 14 Figure 15 

NATIONAL AVERAGE CAPITAL ADDITIONS PILGRIM & NAT AVG. CAPITAL ADDITIONS 



Sp Constant 1986 Dollars per Kilowatt 



45 

40 

35 

30 

25 

20 

15. 

10. 

5 





/ 



280 Constant 1986 Dollars per Kw 
260^ 



/ 
/ 



-1^74r- 197 8 1 96 2 1986 
Year 
, National Average 




-t97Jr 



97 8 ■ 1982" 



Year 

„ Pilgrim . National Avg. 



ESRG Regression 



23 



310 



Figure 16 
CAPITAL ADDITIONS PROJECTIONS 



Constant 1986 Dollars 




1 9 77 ■ 19 6 1 19 65 ' 19 69 1993 ' 1997 2001 20 5 20 9" 

Year 
□ Pilgrim Historical 



cooled plants. ESRG's regression analysis 
has found that capital additions are re- 
lated to plant size, type, cooling water, 
age, year of in, lal operation, and whether 
a plant has one or two units at a site. 

Capital additions at the Pilgrim plant 
have been among the highest of any U.S. 
nuclear plant. Total Pilgrim capital addi- 



tions over the period of 1972 to 1986 
were 3.3 times the national average per 
kilowatt, and considerably higher than 
the regression line for plants of the 
same characteristics (Figure 15). 

Figure 16 displays alternative projec- 
tions of future Pilgrim capital addi- 
tions. Except for one moderately 



Figure 17 

CUMULATIVE SAVINGS FROM RETIRING PILG. 



Sensitivity to Capital Additions 




200 
Year 
NatTrend 



2012 



PilgTrend 



24 



311 



expensive repair planned for 1990, 
Edison forecasts several years of declin- 
ing real expenses for capital additions, fol- 
lowed by a steady outlay of less than $30 
million a year through the year 2007. 
Capital additions are estimated to decline 
by 20 percent per year over the last five 
years of the plant's life. Even Boston 
Edison appears to have little confidence 
in its capital additions estimates, 
however: 

We have provided a reasonable es- 
timate of Pilgrim's costs for the next 
25 years. However, as you know, many 
factors external to the company, such 
as NRC mandated modifications, can 
significantly impact Pilgrim's Custi." 

MASSPIRG's optimistic projection of 
Pilgrim capital additions starts with the as- 
sumption that the four years witn the 
highest capital additions (1980, 1982, 
1984, 1987) were caused by unique events 
~ such as the replacement of cracked 
recirculation pipes in 1984 — which will 
not recur. The remaining years still show 
a consistent underlying pattern of capital 
additions increases which is likely to per- 
sist into the future. To be ultra- conserva- 
tive, the Optimistic Case here assumes 
that this trend continues only for another 
five years. Capital additions are also con- 
servatively assumed to decrease over the 
last five years of the plant's life, even 
though other utilities have testified that a 
higher rate of capit^il additions may be 
needed to keep them running. (See Ap- 
pendix B.) Edison's estimate for 1990 
capital additions is assumed to represent 
a particular planned expenditure which is 
included in MASSPIRG's Optimistic 
Case as well. 

The National Trend Case assumes that 
Pilgrim's rate of capital additions declines 
to the level described by the ESRG 
regression equation, and continues at that 



rate for five years. The Pilgrim Trend 
case assumes that capital additions con- 
tinue at their historic rate (with 1984 
and 1987 additions still defined as non- 
recurring costs) for 10 years. 

Figure 17 illustrates the effect of 
changing only the assumption about fu- 
ture capital additions, holding all other 
BECO assumptions the same. If 
Pilgrim capital additions were to follow 
the National Trend (an improvement 
from the historical performance of the 
plant), it would cost ratepayers very lit- 
tle to retire the plant, even assuming 
full payment of Pilgrim sunk costs, in- 
cluding a profit. 

B. Operation and maintenance 
costs 



Like nuclear capital additions, opera- 
tion and maintenance (O&M) costs 
have also been increasing over time, at 
an average rate of 1 1.4 percent a year 
for the nuclear industry as a whole. At 
Pilgrim, total O&M costs have in- 

Figure 18 

PILGRIM VS. NATIONAL AVG. O&M COSTS 



140 Constant 1986 Dollars per Kw 




^ 974 1 978 



1962-— raee 



Pilgrim 



Year 
National Avg._ ESRG Regression 



25 



312 



Figure 19 
O&M COST PROJECTIONS 
Million Constant 1986$ 




National >enc! 
rim Optimistic 



-1988 1893—1998-— 2603- 



Historical 



creased at an annual rate of 13.8 percent, 
after inflation. Total Pilgrim O&M expen- 
ditures between 1972 and 1986 have ex- 
ceeded the national average per kilowatt 
by 78 percent. Pilgrim O&M expenses 
were less than the regression line for 
plants with Pilgrim's characteristics until 
1983, however (Figure 18). Figure 18 sug- 
gests that management decisions to defer 
maintenance in the early years of Pilgrim 
operation may have contributed to some 
of the plant's later problems. 



Not surprisingly. O&M cost in- 
creases are correlated with many of the 
same variables as capital additions - 
plant size, age, number of units at a 
site, and salt-water cooling. After the 
Three Mile Island Accident in 1979, 
O&M costs increased at all plants by an 
average of $8.55 per kilowatt. In addi- 
tion, plants located in the northeast 
have had O&M costs averaging about 
$8 per kilowatt above plants in other 
regions. 



Figure 20 

CUMULATIVE SAVINGS FROM RETIRING PILG. 
Sensitivity to O&M Costs 




BECO 



Opt 



■1996- 2000 

NatTrend 



-2004 2008^ 2012 

Pilg.Trend 



26 



313 



Figure 21 
HISTORICAL CAPACITY FACTORS 
1 .00 Percent 




Pilgrim 



Year. 



National Avg. 



Alternative projections of O&M costs 
are shown in Figure 19. Edison projects 
substantial increases in O&M costs over 
the next several years, compared to both 
Pilgrim and national trends. A portion of 
the near- term O&M costs also includes 
replacement power costs during extended 
Pilgrim shutdowns that customers are ex- 
pected to pay over several years. After 
1990, however, BECO projects that real 
O&M costs, like capital additions, will sta- 



bilize in constant dollars, mcreasing :u 
only 0.5 percent per year. 

The MASSPIRG Optimistic Case 
projects O&M costs increasing at only 
two percent a year, after adjusting for 
inflation, after 1994. The National 
Trend and Pilgrim Trend cases assume 
that O&M costs eventually resume 
their historical pattern of increase. 

Figure 20 displays the effect of 
changing only the O&M assumption on 
cumulative savings from retiring 
Pilgrim. While significant, the overall 
impact is not as large as that from 
changing capital additions assumptions. 

C. Capacity factor 



The best measure of nuclear plant 
performance is capacity factor - rough- 
ly, the percentage of time a plant is in- 
service at full power. The capacity 
factor of a given plant reflects periods 
that it is shut down for refueling, main- 
tenance and repair. It also accounts for 
times when plants may be forced to 



Figure 22 

CAPACITY FACTOR PROJECTIONS 




19*7? 



-Tms 



^f9Kr 



19 68 1993 

Year 
2-Year Rolling Avg. 



T998- 



2003 



2008^ 



27 



314 



operate at reduced power levels. 

Capacity factors of individual nuclear 
plants tend to var>' a great deal from year 
to year, particularly since most plants are 
refueled every other year, and may be 
taken out of service for several months 
during that time. Across the entire in- 
dustry, however, nuclear capacity factors 
have tended to average consistently just 
under 60 percent. Pilgrim's lifetime 
capacity factor to date is only 50 percent. 
At the point it was shut down in April, 
1986, the plant had averaged a capacity 
factor of 56 percent (Figure 21). 

Some varieties of nuclear plants have 
averaged better performance than others. 
Between 1975 and 1985, for example. 
Pressurized Water Reactors (PWRs) 
averaged capacity factors of 60.8 percent, 
compared to only 56.6 percent for Boiling 
Water Reactors (BWRs) Uke Pilgrim. 
Smaller plants, however, have generally 
achieved higher capacity factors than 
larger plants. Capacity factors of BWRs 
between 400 Mw and 799 Mw, excluding 



the Pilgrim plant, averaged 632 per- 
cent between 1976 and 1986.^^ 

ESRG's regression analysis 
describes capacity factor as a function 
of plant size, general type, type of cool- 
ing water and steam system, and plant 
age. It shows that nuclear plants have 
generally tended to increase capacity 
factors over their first four yeart of 
operation, and experience only flight 
gains in performance over the sub- 
sequent eight years. Reactors that are 
cooled with salt water, like Pilgiim. 
have tended to decline in perforrnance 
each year. 

Figure 22 illustrates ESRG's regres- 
sion equation forecast for a plant of 
Pilgrim's characteristics, and the 
capacity factor projections used in the 
three alternative Pilgrim cost scenarios. 
A two-year rolling average of Pilgrim's 
historical capacity factor is also s^own 
Averaging each year's capacity factor 
with the previous year's helps to 
smooth out the year-to-year ups and 



Figure 23 

CUMUL-ATIVE SAVINGS FROM RETIRING PILG. 



200 



Sensitivity to Capacity Factor 




wir 



28 



315 



downs in capacity factor caused by refuel- 
ing shutdowns every other year. 

Boston Edison assumes that Pilgrim 
will operate at a 70 percent capacity fac- 
tor over the remainder of its life. 
Pilgrim's lifetime capacity factor of 50 
percent ranks 79th among 94 nuclear 
plants. The probability of Pilgrim 
moving from the bottom fifth to well 
above the average capacity factor is quite 
low, particularly in Ught of the trend of 
declining capacity factors in salt-water 
cooled reactors. 

A 63.2 percent capacity factor - the na- 
tional average for small BWRs excluding 
Pilgrim - is used in MASSPIRG's Op- 
timistic Case. A 56 percent capacity factor 
~ equal to Pilgrim's performance before 
the 1986 shutdown and the peak capacity 
factor predicted by the regression equa- 
tion - is used in the National Trend Case. 
Finally, the Pilgrim Trend case assumes 
that the plant will continue to average a 
50 percent capacity factor over the rest of 
its life. These estimates all conservatively 



assume that the declining performance 
of salt-water cooled reactors shown by 
ESRG's regression equation will not 
continue. 

Most of the costs of owning and 
operating a nuclear plant are "fixed 
costs" which do not vary with how much 
electricity the plant actually produces 
in a given year. The iQiai cost of operat- 
ing Pilgrim over the next 25 years ihere- 
fore does not vary much with capacity 
factor. A lower capacity factor means 
that more energy would have to be pur- 
chased to replace Pilgrim, however, 
and means a higher cost for each Kwh 
generated by Pilgrim. 

Figure 23 illustrates the impact of 
capacity factor on the economics of 
retiring Pilgrim. Even if Pilgrim were 
able to maintain the 56 percent 
capacity factor it achieved before its 
April 1986 shutdown, it would save 
ratepayers money through the year 
2003 to retire the plant, even if all 
other BECO assumptions hold. 



29 



316 

Appendix C 

Causes of Nuclear Cost Escalation 



The continuing existence of the factors 
that have contributed to past escalation of 
nuclear capital additions and operations 
and maintenance costs make it likely that 
those expenses will continue to escalate at 
historic rates for the foreseeable future. 
The forces driving the cost escalation in- 
clude the persistence of unresolved safety 
issues, ongoing technical problems that 
are discovered as the nuclear industry 
gains more operating experience, and the 
aging of reactor components. In addition 
to increasing costs, premature aging 
problems also cast serious doubt on 
whether the Pilgrim plant could be 
operated for a 40-year lifetime, as Boston 
Edison projects. 

1. Unresolved generic safety issues. 



The Nuclear Regulatory Commission 
maintains a list of um-esolved safety issues 
which are generic to nuclear power reac- 
tors. As these issues are resolved, they fre- 
quently require significant new expenses 
to implement them. 

Before the 1979 accident at Three 
Mile Island (TMI), the NRC had resolved 
20 of 142 issues identified in its 1978 Task 
Action Plan, according to a 1984 General 
Accounting Office report. The TMI ac- 
cident added many new issues to the 
Commission's Hst, and postponed action 
on many of the previously identified 
problems. By July 1984, the agency had 



resolved only 208 of 482 total issues 
identified through that time. Moreover, 
new issues were being identified at the 
rate of 1 1 per year, while the agency 's 
schedule called for the resolution of 
only 12 total issues per year. As of 
August, 1987, 163 issues remained on 
the unresolved issues list. 



30 



New generic issues are likely to be 
discovered as a result of operating ex- 
perience, particularly as reactors age. 
The possibility of additional major 
nuclear accidents also contributes to 
the likelihood of new regulations. The 
NRC staff has estimated that the prob- 
ability of a full core melt accident at a 
U.S. nuclear plant may be as high as 45 
percent during the next 20 years. 
Other analysts have estimated the prob- 
ability to be higher. 

One unresolved safety problem that 
is of particular concern to Pilgrim is the 
strength of the containment shell which 
is designed to prevent release of 
radioactive materials to the environ- 
ment in the event of an accident. An 
NRC task force has estimated that the 
probability of failure of the Mark I con- 
tainment design used Pilgrim and 25 
other U.S. plants may be as high as 90 
percent in some accident scenarios, 
compared to a failure probability of 

about 10 percent with other contain- 

32 
raent designs. 



30 



317 



Another commission task force is cur- 
rently studying the Mark I problem, but is 
not expected to make recommendations 
for more than a year. There is a substan- 
tial probability that fixing the Mark I con- 
tainment problem will impose costs 
exceeding current BECO estimates. 

2. Ongoing technical problems. 



There is persistent evidence that 
nuclear technology has not yet "matured," 
and that reactor operation will continue 
to be plagued with safety- related and 
non-safety related problems that reduce 
capacity factor and require new O&M 
and capital additions expenditures to fix. 
The mmiber of Licensee Event Reports 
(LERs) -- which document mishaps at 
nuclear plants - has steadily increased. In 
1986, there were 2,957 LERs filed with 
the NRC, approximately the same as the 
record 2,997 LERs for 1985, and well 
above the 2,435 LERs reported in 1984. 
Nuclear plant capacity factors have failed 
to increase as the nuclear industry 
predicted they would as plants matured. 



33 



3. Aging of reactor components. 



The need to replace worn plant com- 
ponents and systems has greatly outpaced 
industry expectations. A 1984 NRC staff 
report identified 5,893 events in safety-re- 
lated systems occurring between 1969 and 
1982 (17 percent of all LERs) as age-re- 
lated. Additional aging problems have oc- 
curred in non- safety-related systems. 
Aging problems have been caused by 
wear and tear, corrosion, internal and ex- 
ternal radiation contamination, contact, 
vibration, stress corrosion, erosion, and a 
category of miscellaneous problems. 



As discussed in the text, salt-water 
cooling systems at reactors located on 
oceans, such as Pilgrim, have been as- 
sociated with more corrosion than 
fresh-water systems. In addition, the 
Pilgrim plant has been subject to much 
higher levels of radiation contamina- 
tion that many other nuclear plants. 
The average Pilgrim worker was ex- 
posed to 1949 rem.<; a yea' between 
1984 and 1986, compared to 645 rems 
per year at Millstone I, in Connecticut, 
a plant the same type and about the 
same age as Pilgrim." ' 

4. Nuclear plant lifetimes. 



In addition to causing mcreasing 
costs for replacement of parts and 
operation and maintenance expenses, 
reactor aging casts serious doubt on the 
ability of nuclear plants to operate for 
the 40 year period assumed by Edison 
in its evaluation of Pilgrim economics. 

Boston Edison's operating license 
for Pilgrim currently expires in 2008, 
after 35 years of operation. The utility 
has recently applied for an extension of 
its Hcense to the year 2012. No license 
extensions for any nuclear plants have 
yet been considered or granted by the 
NRC, however, and there is no way at 
this time of predicting whether such ex- 
tensions will be granted in the future. 

Niagara Mohawk Corporation, the 
chief owner and operator of the Nine 
Mile Point 1 nuclear plant, requested 
permission from the New York State 
PubHc Service Commission to use a 
depreciation life of the plant that is five 
yeais shorter than the plant's operating 
"cense" 

Recognizing the regulatory pres- 
sures from the Nuclear Regulatory 



31 



318 



Commission, relicensing should not 
be assumed. If it should happen that it 
is possible to relicense the plant, the 
capital expenditures required would 
be of such a magnitude that the unit, 
for depreciation purposes, should be 
considered as being new at that 
time.-'^ 

Niagara Mohawk's testimony, in addi- 
tion to contradicting BECO's assumption 
of relicensing, also contradicts Edison's 
assumption that capital additions expendi- 



tures would not increase in real terms 
over the entire last 25 years of the 
plant's projected life, and would 
decrease at 20 percent per year over 
the last five years. 

To date, no conmiercial nuclear plant 
has yet operated for longer than 27 
years (Table 4), and a significant num- 
ber of reactors have been retired with 
considerably fewer years of operation. 
(Table 5) 



TabU 4. OLDEST U^. OPERATING NUCLEAR REACTORS 


Plant 


Location 


Initial 


A«e 


Capacity 






Operation 




Yankee 


Rowe, MA 


1960 


27 


185 


Big Rock PoiM 


Charievoix, Ml 


1962 


25 


75 


San Onofre 1 


San aemente, CA 


1967 


20 


450 


Haddam Neck 


Haddam Neck, CT 


1967 


20 


600 


Oyster Creek 


Forked River, NJ 


1969 


18 


550 


Nine MUe Point! 


Scr»ba,NY 


1969 


18 


642 


Gmna 


Ontario, NY 


1969 


18 


517 


Dresdea 2 


Morris, IL 


1970 


17 


794 


Robinson 2 


Hartsviile, SC 


1970 


J7 


769 


Point Beach 1 


Two Creeks, Wl 


1970 


17 


485 


Millstone I 


Waterford, CT 


1970 


17 


660 


Sorurce: Critical Mass Energy Project;^ Nuclear Regulatory 


Commission 







Table 5. RETIRED U.S. REACTORS 



Plant 



Initial 
Operation 



Retirement 
Year 



32 



Capacity 



Three Mile Island 2 


; ■■ 1978 


1979 


1 


906 


Pathfinder 


:>: 1966 


1967 


1 


66 


Haifam 


.:.: 1963 


1964 


1 


256 


Piqua 


1963 


1966 


2 


45 


CVTR 


1963 


1967 


3 


65 


m:: Bonus 


1964 


1968 


4 


50 


={;v Elk River 


;<■; 1963 


1968 


4 


22 


Fermi 1 


1966 


1972 


6 


61 


:>: Peach Bottom 1 


1967 


1974 


8 


40 


Indian Point 1 


1962 


1974 


12 


265 


Humboldt Bay 


1963 


1976 


13 


65 


Dresden 1 


1960 


1978 


19 


207 



319 



Notes 



A federal study estimated subsidies for research and development, mining and fuel enrichment at almost 
$40 billion by 1981. (Joseph Bowring, "Federal subsidies to Nuclear Power," unpublished report, Olfic*; of 
Economic Analysis, Energy Information Administration, March 1980. Another estimate of construction 
subsidies to nuclear power plants runs as high as $15.6 billion for the year 1984 alone. (H. Richard Heede. 
Richard E. Morgan, and Scott Ridley, The Hidden Costs of Energy: How Taxpayers Subsidize Energy 
Development, Center for Renewable Resources, Washington, D.C., October, 1985) 

^See Nuclear Waste Fee Adequacy: An Assessment, U.S. Department of Energy, Office of Civilian Radioac- 
tive Waste Management, DOE/RW- 0020, June 1987, pp. 7-10; Commercial Nuclear Power: Prospects for 
the United States and the World, U.S. Department of Energy/Energy Information Administration, 
DOE/EIA-0438(86, p. 20); "Nuclear Power Plant Decommissioning: Cost Estimation for Power Plaiming 
and Ratemaking," Energy Systems Research Group, Boston, July, 1987. 

^Charles Komanoff, Power Plant Cost Escalation, Komanoff Energy Associates, New York, 1981 . 

^avid Schlissel, Trends for Nuclear Capital Additions and O&M Costs," Direct Testimony Before the 
Public Service Commission of the State of Missouri Appearing for the Office of the Public Counsel, Case 
No. ER-85-128, Case No. EO-85-185, June 28, 1985. 

^Nuclear Plant Cancellations: Causes, Costs and Consequences, U.S. Department of Energy/Energy Infor- 
mation Administration, DOE/EIA-0392, April 1983. 

Schlissel, op. cit. 

'' Richard Hellman and Caroline J.C. Hellman, The Competitive Economics of Nuclear and Coal Power, 
Lexington Books: Toronto, 1983. 

^Richard McCormack, "Whoops!" Energy Daily, April 28, 1986, p. 1 

'Joseph Kricsberg, Nuclear Power Too Costly to Continue , Draft, Criti ral Ma« Energy Project, 
Washington. D.C.. November 1987 

Ibid., from U.S. Department of Energy communication. 

Schlissel, op. cit. 

^^illiam Blundell, "Doubts Pervade Nuclear Fuel Industry Utility Pacts Unclear; Uranium Producers 
Ailing," The Wall Street Journal, October 10, 1985; Kennedy Maize, 'Doraenici's Uranium Bill Would Trim 
imports to 50 Percent of U.S. Needs," The Energy Daily, February 20, 1986. 

^Power to Spare: A Plan for Increasing New England's Competitiveness Through Energy Efficiency, New 
England Energy Policy Cotmcil, July 1987. 

Fvial Report of the Boston Edison Review Pane l, March 1987. 

^NEPOOL Forecast Report of Capacity, Energy, Loads and Transmission 1987- 2002, New England Power 
Pool, West Springfield, MA, April 1, 1987. 

'^Boston E^soa, Request for Proposals from Qualifying Cogeneration and Small Power Production 
Facilities, Appendix C, Exhibit 4, p. 18. 

^^Final Report: Asset Disposal and Contract Settlement Associated With Pilgrim 2 Cancellation, Boston 
Edison Company, Report #10, May, 1987 

^^estem Massachusetts Electric Company, D.P.U. 84-25. 

^Western Massachusetts Electric Company, D.P.U. 85-270 

Nuclear Plant Cancellations, op. cit, » 



33 



320 



^Harvey Salgo, Raymond Czahar, and Paul Raskin, TrofKJsal of the Executive Office of Energy Resour- 
ces, DP.U. 86-36, April 4, 1986. 

^^quations for this study were talcen from the Testimony of Stephen Bemow on "Excess Capacity and 
Cost Benefit Analysis of Vogtle Generating Station" on behalf of the Georgia Office of Consumers' Utility 
Counsel before the Georgia Public Service Commission, Docket No. 3673-U, August, 1987. 

^Carl Gustin, Vice President, Corporate Relations, Boston Edison, Letter to Sharon Pollard, Secreatary 
of Energy Resources, Commonwealth of Massachusetts, June 8, 1987. Also referred to as Exhibit 1. Ex- 
hibit 2 is Carl Gustin letter of July 1, 1987.. 

Gustin, personal communication, October 1987. 

^^ESRG; Equipment Availability Report 1976-1985, North American Electric ReUability Council, Prin- 
ceton, NJ. 

''ibid. 

^rom Monthly Operating Reports filed with the U.S. Nuclear Regulatory Commission, courtesy of 
Stephanie Murphy, Nuclear Information and Resource Service, Washington, D.C. 

^Management Weaknesses Affect Nuclear Regulatory Commission Efforts to Address Safety Issues 
Common to Nuclear Power Plants," General Accounting Office, GAO/RCED-84-19, September 19, 
1984). 

^""Efforts to Ensure Nuclear Power Plant Safety Can Be Strengthened," General Accounting Office, 
GAO/RCED-87-141, August, 1987. 

" NRC Testimony to U.S. House of Representatives, Subcommittee on Energy Conservation and Power, 
April 1986. 

Brian Jordan, "Denton Urges Industry to Settle Doubts About Mark 1 ContJiinmenl," Inside N-R-C, 
June 9, 1986, p. 1. 

^^Joshua Gordon, 1986 Nuclear Power Safety Report, Public Citizen, Washington, DC, September 1987. 

Survey of Operating Experience from LERs to Identify Aging Trends, Status Report," Nuclear 
Regulatory Commission, NUREG/CR-3543, January 1984. 

David Wesscl, "Pilgrim and Millstone, Two Nuclear Plants, Have Disparate Fates," The Wail Street Jour- 
nal, My 78, 1981., p. I. 

John S. Ferguson, Prepared testimony on behalf of the Niagara Mohawk Power Corporation in New 
York Public Service Commission Case #28225, p. 27. 



34 



321 

The Chairman. In one of the reports you talked about the sub- 
ject of advance pubhc information and education. And there are 
some that would say that those people claim not to know the evac- 
uation procedures, that they are against the plan anyway, so it is 
not their interest to be helpful; that it is not in their interest to tell 
you, even if they read the plan, that they had read the plan, if they 
thought they would be helpful to Boston Edison. How do you re- 
spond to that criticism? That is a criticism that may be made. 

Ms. Shimshak. Having participated in a survey, people gave us 
very honest answers. I believe that they told you the truth when 
they said they didn't really know what to do in the event of an 
emergency and they said they hadn't actually received the emer- 
gency information booklet in the mail. 

One thing that did stand out with people's answer to these ques- 
tions is an air of cynicism. Having been through 15 years worth of 
history of this plant, and seeing how many problems it has and ex- 
periencing the NRC's lack of attention to those plans — those prob- 
lems, I think people have a very cynical view. And even if they 
were given proper instructions, my guess is they wouldn't follow 
them. They'll get together with their families because that's what's 
most important to them and they'll do what they think is best at 
the moment, and I don't believe that that will be following the pre- 
scribed directions. 

The Chairman. Are you, from your own perspective, optimistic 
or pessimistic as to whether that plant will restart? 

Ms. Shimshak. Well, I would be tempted to say that I'm pessimis- 
tic just because of the NRC's record in the past, and given the fact 
that they never really shut a plant down for being £is bad as Pil- 
grim is. But I must admit, I'm feeling optimism for two reasons, 
and one is that you've taken an interest in this plant, as well as 
many other elected officials, and, hopefully, that will stimulate 
some good action on this; and also since the plant has been shut 
down for 21 months, which I don't believe any of us would have 
expected in 1986 when it originally closed down. 

The Chairman. Thank you very much— you're a very helpful 
panel, these are helpful reports. Wish we had more time to go into 
the issues. I may want to submit some more questions to you, but 
we appreciate the time. We are very much impressed — but not sur- 
prised — by the quality of the representation of the member of the 
great general court, the State Senate. By your testimony obvious- 
ly — as well as Mr. Malaguti's testimony, and the very exemplary 
work that has been done. I want to thank all of you very much. 

[One-minute break.] 

The Chairman. I want to announce for the record, we were not 
able to include all the State Representatives and Senators in the 
course of our hearing. We had about 10 or 12 that had made appli- 
cations. We want to indicate to any of those that want to have 
their statements made a part of the record, including the State sen- 
ator that represents the local community that we will include 
them. 

We tried to get the State representative, the Board of Selectmen 
and the chairman of the Energy Committee in the Great General 
Court. But we want to indicate to everyone, if they want their 
statement included in the record, we will keep the record open. But 



322 

it was really a question of trying to hear from as many of the dif- 
ferent representatives who have interest and responsibilities in the 
local community, from the local representatives as well as the rep- 
resentatives of the NRC. 

We wanted to hear all of them and not to try to go below a 3 or 4 
minutes presentation; otherwise, you lose the real context of the 
hearing. So those are the reasons, quite frankly. We were not in- 
tending to be disrespectful to any of those persons. 

We are particularly delighted now to have here an old friend of 
mine, and one of our very fine public servants, the Lieutenant Gov- 
ernor of our State, Evelyn Murphy. I welcome her to our hearing 
as the second ranking State official in a position of responsibility in 
the State for its health and well being, as she brings a special per- 
spective to this hearing, and we very much look forward to her tes- 
timony. I'll ask that you be good enough to stand and take the 
oath. 

[Lieutenant Governor Murphy sworn.] 

STATEMENT OF LT. GOV. EVELYN MURPHY 

Lieutenant Governor Murphy. Thank you Senator Kennedy. I 
want to thank you for giving all of us the opportunity to come here 
tonight and discuss the Pilgrim nuclear power plant and the seri- 
ous public health and safety questions surrounding it. And you've 
seen the turnout tonight on one of the coldest nights of this winter, 
it is the testimony to the intense feelings that people have about 
the issue. 

I come here tonight, not just as Lieutenant Governor, but as the 
Acting Governor to express the Governor's and my concern about 
the threat to the public's health and safety of this plant, and insist 
on behalf of the people of the Commonwealth of Massachusetts 
upon two very reasonable specific actions. 

First that the NRC hold an adjudicatory hearing in Plymouth 
before this plant opens; and second, that Pilgrim not be allowed to 
reopen until the emergency evacuation concerns of both FEMA and 
Governor Dukakis have been satisfactorily resolved. 

In June of 1986, the plant was closed because of serious charges 
concerning the safety of the management facility. I won't dwell on 
the specifics. You are going to hear from a panel of State officials 
here tonight: Mr. Agnes, the Assistant Secretary of Public Safety; 
Commissioner of Public Health, Deborah Prothrow-Smith; Attorney 
General; Secretary Pollard, all prepared to supply in detail from 
the State's perspective, the concerns that Governor Dukakis and I 
share. 

Since the closing of this facility. Governor Dukakis has laid out 
three preconditions for its reopening. Public health and safety are 
the crux of these criteria. First, the inadequate safety practices at 
the plant must be corrected; second, the management problems 
must be resolved, and third, the evacuation plan must be adequate. 
These three criteria have been offered as reasonable demands for 
the operation of the nuclear power plant in a heavily populated 
area. They have not yet been met by Boston Edison. 

This administration has the responsibility to protect our citizens. 
And our insistence that the plants be operated with protection of 



323 

people's health and safety as the foremost guarantee is absolutely 
non-negotiable. 

My own reservations about this plant and nuclear power date 
back to 1975 when I rejected the draft Environmental Impact 
Report for Pilgrim 2. At that time the comments were on the ques- 
tions of disposal of waste and about plant safety. Those issues are 
the same, and remain unanswered today. So my reservations have 
become more resolutions: the resolve to prevent our safety and eco- 
nomic health from being held hostage to any one power source; and 
the resolution to work toward the development of safe, reliable, 
non-nuclear energy. 

As you deliberate here tonight on the future of the Pilgrim 
plant, please disregard the issues involved in supply and demand 
on the New England power grid. Let me be very clear. We have 
sufficient energy generating capacity for all but the most unusual 
situations today. As a matter of fact, Tuesday night, demand hit a 
record-breaking peak of 18,471 megawatts, that was met through 
contingency purchases and other standard operating procedures, 
once we hit those contingency plans. So meeting even high electric- 
ity demands is possible without Pilgrim, without Seabrook and 
without a crisis. 

Today's problems of tight energy in New England are more due 
to the lack of judicious management and maintenance practices, as 
well as the needs of aggressive action on short term augmentation 
of supplies, as was just discussed by the panel; some of the small 
scale power that could be brought on line quickly, and some of the 
energy conservation load management practices that have certain- 
ly been recommended and are possible. 

In recent months, the State has been very active to do this, and 
we're pulling together a task force, at the Governor's request, so 
the state can move aggressively on these initiatives to augment 
supply and dampen demand. So we are doing that. And I would 
only say to you that I would hold that question about the New Eng- 
land power supply aside. It has no relevancy whatsoever tonight. 

Having expressed these concerns to you, I must say that I realize 
how difficult it is for you. Governor Dukakis, me and other respon- 
sible public officials to make any headway against an unresponsive 
Federal bureaucracy, which actually doesn't seem to care about the 
health and safety of the citizens of the State. 

It seems to me that the NRC has been surprisingly nonrespon- 
sive to date. Let me be more specific, and go through a little bit of 
the sequence here. In July of 1986, as Senator Golden mentioned, I 
joined him, MASSPIRG, and many other in signing that show 
cause petition for addressing three points on nuclear reactor safety, 
emergency planning and maintenance. The NRC rather callously 
dismissed the first two and deferred consideration on the third 
point. MASSPIRG appealed denials, and Attorney General Shan- 
non, who is about to testify after me, is now an intervener in those 
appeals. And yet there has been no response. I find this difficult to 
accept. 

In October of 1987, Governor Dukakis and Attorney General 
Shannon filed a show cause petition asking for the adjudicatory 
hearings on whether this plant should be allowed to reopen. There 
has been no response. Nor has the NRC responded to a substan- 



324 

live — in a substantive manner — to the two reports on Pilgrim pre- 
pared by Secretary of Public Safety Charles Barry, and submitted 
by Governor Dukakis at first on December 1, 1986; the second De- 
cember of 1987. And it is now my understanding, Senator, you and 
Congressman Studds also submitted a request that has been denied 
in term of appeal to an adjudicatory hearing. 

NRC has indicated that it will meet with petitioners, and this, I 
believe, for all of us is unacceptable. Citizens of the State have a 
right to see this case argued in a formal setting. I would encourage 
you to do everj^hing in your power to see that this hearing takes 
place. You have my commitment and the Governor's commitment 
to fully support your efforts. 

What the Governor and the people of Massachusetts have put 
before the NRC, we believe to be specific and reasonable requests, 
but when confronted by bureaucratic stonewalling, that reasonable- 
ness is likely to turn out to be more increasing outrage. 

In closing, let me make one final point regarding FEMA and the 
NRC. As you know, currently FEMA's role is strictly advisory. This 
has been mentioned several times. The situation here is a prime 
example of how the NRC could overrule the recommendations of 
both the Governor and FEMA, as it's own advisory body. This is 
absurd. 

The Governor and I would wholeheartedly support any congres- 
sional action that you would take in passing a requirement that 
the NRC be bound by the recommendations of the State govern- 
ment and of FEMA. For Massachusetts, that would mean that Pil- 
grim would not restart until the people of Massachusetts were sat- 
isfied with the emergency plan. 

We thank you once again for doing this tonight and for your in- 
volvement and we're really quite grateful. 

[The prepared statement of Lieutenant Governor Murphy fol- 
lows:] 



325 




EVELYN F MURPHY 
LIEUTENANT GOVERNOR 



THE COMMONWEALTH OF MASSACHUSETTS 
EXECUTIVE DEPARTMENT 

STATE HOUSE • BOSTON 02133 



ROOM 259 
(617) 727-7200 



TESTIMONY OF LIEUTENANT GOVERNOR EVELYN F. MURPHY 

UNITED STATES LABOR AND HUMAN RESOURCES COMMITTEE 

JANUARY 7 , 1988 

SENATOR KENNEDY, MEMBERS OF THE COMMITTEE. I WANT TO THANK 
YOU FOR GIVING US ALL THE OPPORTUNITY TO COME HERE TONIGHT TO 
DISCUSS THE PILGRIM NUCLEAR POWER PLANT AND THE SERIOUS PUBLIC 
HEALTH AND SAFETY ISSUES SURROUNDING IT. 

THE TURNOUT TONIGHT, ON ONE OF THE COLDEST NIGHTS OF THE 
WINTER, IS TESTIMONY TO THE FEELINGS PEOPLE HAVE ABOUT THIS 
ISSUE. 

I COME HERE TONIGHT AS ACTING GOVERNOR TO EXPRESS THE 
GOVERNOR'S AND MY CONCERNS ABOUT THE THREATS TO PUBLIC HEALTH 
AND SAFETY POSED BY THIS PLANT, AND TO INSIST, ON BEHALF OF THE 
PEOPLE OF THE COMMONWEALTH OF MASSACHUSETTS, UPON TWO VERY 
REASONABLE, SPECIFIC ACTIONS. FIRST, THAT THE NRC HOLD AN 
ADJUDICATORY HEARING HERE, IN PLYMOUTH, BEFORE THIS PLANT 
OPENS. SECOND, THAT PILGRIM NOT BE ALLOWED TO REOPEN UNTIL THE 
EMERGENCY EVACUATION CONCERNS OF BOTH FEMA AND GOVERNOR DUKAKIS 
HAVE BEEN SATISFACTORILY RESOLVED. 



326 



IN JUNE 1986, THE NRC AND BOSTON EDISON ANNOUNCED THE 
TEMPORARY CLOSING OF THE PILGRIM PLANT, BECAUSE OF SERIOUS 
CHARGES CONCERNING THE SAFETY AND MANAGEMENT OF THE FACILITY. I 
WILL NOT DWELL ON THE SPECIFICS OF THIS MATTER. MR. AGNES, THE 
ASSISTANT SECRETARY OF PUBLIC SAFETY AND DR. PROTHROW-STITH , THE 
COMMISSIONER OF PUBLIC HEALTH, ARE PREPARED TO PROVIDE DETAILED 
DOCUMENTATION TO YOU AND THE COMMITTEE ABOUT THE CONCERNS 
GOVERNOR DUKAKIS AND I SHARE. 

SINCE THE CLOSING OF THE FACILITY, GOVERNOR DUKAKIS HAS 
LAID OUT THREE PRECONDITIONS FOR ITS REOPENING; PUBLIC HEALTH 
AND SAFETY fi^E AT THE CRUX OF THOSE CRITERIA. 

FIRST, THE INADEQUATE SAFETY PRACTICES AT THE PLANT MUST BE 
CORRECTED; SECOND, THE MANAGEMENT PROBLEMS MUST BE RESOLVED; AND 
THIRD, THE EVACUATION PLAN MUST BE ADEQUATE. 

THESE THREE CRITERIA HAVE BEEN OFFERED AS REASONABLE 
DEMANDS FOR THE OPERATION OF A NUCLEAR POWER PLANT IN A 
HEAVILY-POPULATED AREA. AND THESE THREE CRITERIA HAVE NOT YET 
BEEN MET BY BOSTON EDISON. THIS ADMINISTRATION HAS THE 
RESPONSIBILITY TO PROTECT OUR CITIZENS. OUR INSISTENCE THAT THE 
PLANT BE OPERATED WITH PROTECTION OF PEOPLE'S HEALTH AND SAFETY 
AS THE FOREMOST GUARANTEE IS ABSOLUTELY NON- NEGOTIABLE . . 



327 



t-IY OWN RESERVATIONS ABOUT PILGRIM AND NUCLEAR POWER IN 
GENERAL, DATE BACK TO 1975, WHEN I SERVED AS SECRETARY OF 
ENVIRONMENTAL AFFAIRS IN THE FIRST DUKAKIS ADMINISTRATION. AT 
THAT TIME, I REJECTED THE DRAFT ENVIRONt'lENTAL IMPACT REPORT FOR 
PILGRIM II BECAUSE OF UNRESOLVED WASTE DISPOSAL PROBLEMS AND 
QUESTIONS ABOUT PLANT SAFETY. THESE ISSUES REMAIN UNRESOLVED TO 
THIS DAY. 

SO, MY RESERVATIONS HAVE BECOME RESOLUTIONS: RESOLUTION TO 
PREVENT OUR SAFETY AND ECONOMIC HEALTH BEING HELD HOSTAGE TO ANY 
ONE POWER SOURCE; AND RESOLUTION TO WORK TOWARD THE DEVELOPMENT 
OF SAFE, RELIABLE, NON-NUCLEAR ENERGY. 

AS YOU DELIBERATE ON THE FUTURE OF THE PILGRIM PLANT, 
PLEASE DISREGARD THE ISSUES INVOLVING SUPPLY AND DEMAND ON THE 
NEW ENGLAND POWER GRID. LET ME BE VERY CLEAR: WE HAVE 
SUFFICIENT ENERGY GENERATING CAPACITY FOR ALL BUT THE MOST 
UNUSUAL SITUATIONS. AS A MATTER OF FACT, TUESDAY NIGHT, DEMAND 
HIT A RECORD-BREAKING PEAK OF 18,471 MW, AND WAS MET THROUGH 
CONTINGENCY PURCHASES AND OTHER STANDARD OPERATING PROCEDLTRES. 
SO, MEETING EVEN UNUSUALLY HIGH ELECTRICITY DEMANDS IS POSSIBLE 
WITHOUT PILGRIM, WITHOUT SEABROOK, AND WITHOUT CRISIS. 

TODAY'S PROBLEMS OF TIGHT ENERGY IN NEW ENGLAND DERIVE FROM 
LACK OF JUDICIOUS MAINTENANCE SCHEDULING AND PRACTICE; A LACK OF 
AGGRESSIVE PERFORMANCE TO EASE DEMAND THROUGH CONSERVATION AND 
LOAD MANAGEMENT: AND A LACK OF STRONG PURSUIT OF SMALL SCALE 
POWER PLANTS TO AUGMENT SUPPLY. 



328 



IN RECENT MONTHS THE STATE HAS BEEN VERY ACTIVE. THE 
GOVERNOR HAS ASKED ME TO WORK WITH SECRETARY POLLARD, SECRETARY 
GOLD, SECRETARY HOYTE , THE DEPARTMENT OF PUBLIC UTILITIES, THE 
DEPARTMENT OF CAPITAL PLANNING AND OPEPvATIONS AND THE GOVEPJ^OR'S 
ECONOMIC DEVELOPMENT OFFICE SO THE STATE CAN MOVE AGGRESSIVELY 
ON THESE INITIATIVES TO AUGMENT SUPPLY AND DANfPEN DEMAND. AND 
WE ARE DOING JUST THAT. 

HAVING EXPRESSED THESE CONCERNS TO YOU, SENATOR, I MUST SAY 
I REALIZE HOW DIFFICULT IT IS FOR YOU, GOVERNOR DUKAKIS, ME AND 
OTHER RESPONSIBLE PUBLIC OFFICIALS TO MAKE ANY HEADWAY AGAINST 
AN UNRESPONSIVE FEDERAL BUREAUCRACY, A BUREAUCRACY THAT REALLY 
DOESN'T SEEM TO CARE ABOUT THE HEALTH AND SAFETY OF THE CITIZENS 
OF THIS STATE. IT SEEMS TO ME THAT THE NUCLEAR REGULATORY 
COMt'lISSION HAS BEEN SURPRISINGLY NON-RESPONSIVE IN DEALING WITH 
THE MASSACHUSETTS GOVERNMENT AND THE PUBLIC ABOUT THIS 
FACILITY. 

LET ME BE SPECIFIC. IN JULY OF 1986, I JOINED SENATOR 
WILLIAM GOLDEN, MASSPIRG AND MANY OTHERS IN SIGNING A SHOW CAUSE 
PETITION ADDRESSING THREE POINTS: REACTOR SAFETY; EMERGENCY 
PLANNING; AND MAINTENANCE. THE NRC RATHER CALLOUSLY DISMISSED 
THE FIRST TWO, AND DEFERRED CONSIDERATION OF THE THIRD POINT. 
MASSPIRG HAS APPEALED THE DENIALS, AND ATTORNEY GENERAL JAMES 
SHANNON IS NOW AN INTERVENER IN THE APPEAL; YET THERE HAS BEEN 
NO RESPONSE. I FIND THIS VERY DIFFICULT TO ACCEPT. 



329 



IN OCTOBER, 1987, GOVERNOR DUKAKIS AND ATTORNEY GENERAL 

JAMES SHANNON FILED A SHOW CAUSE PETITION ASKING FOR AN 

ADJUDICATORY HEARING ON WHETHER THIS PLANT SHOULD BE ALLOWED TO 
REOPEN. THERE HAS BEEN NO RESPONSE. 

NOR HAS THE NRC RESPONDED IN A SUBSTANTIVE MANNER TO THE 
TWO REPORTS ON PILGRIM, PREPARED BY SECRETARY OF PUBLIC SAFETY 
CHARLES BARRY AND SUBMITTED BY GOVERNOR DUKAKIS, THE FIRST IN 
DECEMBER 1986, THE SECOND IN DECEMBER 1987. 

AND, SENATOR, I UNDERSTAND THAT THE NRC HAS DENIED THE 
REQUEST WHICH YOU AND CONGRESSMAN GERRY STUDDS SUBMITTED ASKING 
FOR AN ADJUDICATORY HEARING ON PILGRIM. 

THE NRC HAS INDICATED THAT IT WILL MEET WITH THE 
PETITIONERS. THIS IS UNACCEPTABLE. THE CITIZENS OF THIS STATE 
HAVE THE RIGHT TO SEE THIS CASE ARGUED IN A FORMAL SETTING. I 
WOULD ENCOURAGE YOU, SENATOR, TO DO EVERYTHING IN YOUR P0\7ER TO 
SEE THAT THIS HEARING TAKES PLACE. YOU WILL HAVE THE GOVERNOR'S 
AND MY FULL SUPPORT IN YOUR EFFORTS. 

WHAT THE GOVERNOR AND THE PEOPLE OF MASSACHUSETTS HAVE PUT 
FORTH ARE SPECIFIC AND REASONABLE REQUESTS AND SUGGESTIONS. BUT 
WHEN CONFRONTED BY SUCH BUREAUCRATIC STONEWALLING, A VOICE OF 
REASON COULD BECOME TRANSFORMED INTO A VOICE OF OUTRAGE. IT IS 
AN UNCONSCIONABLE ATTITUDE ON THE PART OF A PUBLIC AGENCY 
SUPPOSEDLY CHARGED WITH PROTECTING PUBLIC HEALTH AND SAFETY. 



330 



IN CLOSING, LET ME MAKE ONE FINAL POINT REGARDING FEMA AND 
THE NRG. AS YOU KNOW, CURRENTLY FEMA ' S ROLE IS STRICTLY 
ADVISORY. HOWEVER, THE SITUATION HERE IS A PRIME EXAMPLE OF HOW 
THE NRC COULD OVERRULE THE RECOMMENDATIONS OF BOTH THE GOVERNOR 
OF A STATE AND ITS OWN ADVISORY BODY BY ALLOWING PILGRIM TO 
REOPEN DESPITE FJCPERT OPINION TO THE CONTRARY. THIS IS AN 
ABSURDITY. THE GOVERNOR AND I WOULD WHOLEHEARTEDLY SUPPORT ANY 
CONGRESSIONAL EFFORT TO GET LEGISLATION PASSED WHICH WOULD 
REQUIRE THE NRC TO BE BOUND BY THE RECOMMENDATIONS OF A GOVERNOR 
AND FEMA. 

FOR MASSACHUSETTS, THIS WOULD MEAN THAT PILGRIM WOULD NOT 
RESTART UNTIL THE PEOPLE OF MASSACHUSETTS WERE SATISFIED WITH 
THE EMERGENCY PLANS. 

THANK YOU. 



331 

The Chairman. Thank you very much. We're grateful for your 
presence here, for your taking the time. 

(Let me ask you. Given the Governor's position on the Seabrook 
amt on the Pilgrim, what is the implication, due to the fact that 
nuclear power provides some 33 percent of the power resources for 
New England, if Seabrook isn't opened and Pilgrim is not re- 
opened, what are the energy implications going to be in terms of 
Massachusetts, and responding first of all, and then respond to the 
point that the legislators made in terms of increasing pressures in 
term of the growth in the future. How are we going to deal with it? 

Lieutenant Governor Murphy. Well, I think those matters go 
hand in hand. We have right now sufficient energy on the power 
grid to respond to even the most extreme matters that we see right 
now, for instance that we had this summer. 

The real issues before us are how to move now to augment our 
supply. There are lots of proposed plants for small scale cogenera- 
tion, hydroelectric, environmentally sound, small scale plants now 
in the licensing proceedings within the State government — we are 
looking to expedite those. There is the equivalent of one Pilgrim 
plant right now within that licensing procedure. So we can see 
ways in the short term to augment supplies. I think we can also 
see ways in the short term to dampen some of the demands, conser- 
vation and load management procedures, and also to take some 
action which even includes the planning, which we have been 
doing the last couple of days, to ask the utility companies to get 
more aggressive concerning interrupting rate contracts. 

So in the short term. Senator, we believe very strongly that there 
is sufficient power for not only meeting today's demands, but in the 
short-term summer growth. Over the longer trek, there is no doubt 
that in the mid 1990's, the Federal Reserve Board study is a wise 
and sound one, and that we'll need to look at some larger scaled 
plants to be brought on line. That explains some of the Governor's 
initiatives around natural gas, and the initiatives right now to look 
at increased resources from HydroQuebec, and our looking at even 
Edgar Station. 

So we see a way right now of moving from the overreliance of 
nuclear power to other options, diversifying what we have for all of 
New England power, which makes us feel safer and insures the 
kind of reliabilities, so that we can continue to have a sustained 
economic growth and the jobs that we now enjoy, but it means get- 
ting on with this. And I think the faster we can put to rest the con- 
troversies of nuclear power and all the other options, the healthier 
and safer and more reliable our energy sources are going to be. 

The Chairman. I thank you very much. I think in your summa- 
tion of the three major criteria which are necessary before you and 
the Governor will support an opening of the plant, you have cap- 
sulized the essence of the argument. All the rest of your presenta- 
tion certainly supports it. I want to thank you very much for 

Lieutentant Governor Murphy. Thank you. 

The Chairman [continuing]. Joining us. We're grateful for your 
participation in this matter. Thank you. 

Our next witness is our Attorney General Jim Shannon. He is a 
long-time, personal friend of mine, who was very much involved in 
the Pilgrim question even before he assumed his present position. 



332 

He is an uniquely qualified person. Some of the ramifications of 
the legal relationships between the State and Federal government 
in the nuclear power field, this is an issue I know, General, that we 
heard about earlier in the course of our hearing, but there have 
been a good deal of comments from a number of witnesses about 
how this relationship could be adjusted or changed, in order that 
the principal health concerns and safety concerns and the manage- 
ment concerns can be addressed by the public and by the State offi- 
cials. So we're enormously interested in your own views on those 
subjects, as well as what the current state of the situation is, and 
what actions you are proposing to take should there be a decision 
to move ahead. We look forward to your testimony, and we'll ask 
you to be kind enough to stand. 
[Attorney General Shannon sworn.] 

STATEMENT OF ATTORNEY GENERAL JAMES SHANNON 

Mr. Shannon. Thank you, Senator Kennedy. I want to thank 
you for holding this hearing this evening, and also for the leader- 
ship that you have brought to this very important issue to the 
people of the Commonwealth and in the U.S. Senate. 

The issue before you, the health implications of restarting the 
Pilgrim nuclear power plant is one of tremendous importance to 
everybody in the Commonwealth, but particularly to those people 
who are neighbors to this plant. I commend you, too, for coming 
here tonight so that the people who have been shut out of the proc- 
ess can finally be heard. 

The facts of this case have been very well documented. The NRC 
currently ranks Pilgrim as one of the worst managed plants in the 
country. This past summer, the General Accounting Office reported 
that most of Pilgrim's management deficiencies remained uncor- 
rected. In 1982, the NRC fined Boston Edison $550,000 for submit- 
ting false information to the NRC and improperly operating Pil- 
grim. 

By 1985, the utility had paid additional civil penalties totaling 
$90,000. In fact, between 1983 and 1985, the NRC cited Pilgrim for 
52 violations, ranging from operations to surveillance and radiolog- 
ical control. Finally, in April 1986, Boston Edison shut Pilgrim 
down. 

These facts compel an open process, one in which Boston Edison 
will be required to prove to the public that its problems are solved. 
Instead, it appears the NRC intends to decide the fate of this plant 
on the basis of a closed inspection and evaluation. 

The people of the Commonwealth deserve better than that. No 
one should consider reopening the Pilgrim nuclear power plant 
until there has been a full adjudicatory hearing, which clearly 
demonstrates that these problems have been solved. 

Senator Kennedy, both you and Congressman Studds have been 
forceful in calling for these hearings. The NRC's response that a 
public meeting be held is completely inadequate, if we are to insure 
public health and safety. 

In 1986, before my election as attorney general, I was a petition- 
er along with several others here tonight, calling for a full adjudi- 
catory hearing on the reopening of this plant. As Attorney Gener- 



333 

al, I, along with Governor Dukakis, filed a second petition for the 
same full legal proceeding. The NRC essentially rejected the first, 
and has yet to act on the second. The private petitioners have ap- 
pealed the rejection by the NRC, and my office is taking a lead role 
in that litigation. 

I continue to be deeply concerned, not only about the threat this 
plant poses to public health and safety, but the unwillingness of 
both the utility and the NRC to address both these issues in an 
open hearing. The NRC has a formal hearing process and they 
should use it if they expect to restore public confidence in this pow- 
erplant. 

These two petitions are straightforward. They call for the NRC 
to hold a hearing in which Boston Edison must prove it can operate 
this plant safely and effectively; a hearing in which we can cross 
examine the company's and the NRC's experts, and offer our own 
independent experts to review the facts; a hearing in which the 
NRC must issue a written decision which is subject to review in 
courts. The public deserves a full hearing on the safety of this trou- 
bled nuclear plants. Boston Edison must be held to a burden of 
proof in an adjudicatory hearing to show that it can operate the 
plant safely, something which it has yet to prove. 

Over the past year as attorney general, I've been deeply involved 
in the very serious questions surrounding the regulation of the nu- 
clear power industry, both here at Pilgrim and through the licens- 
ing process of the Seabrook plant in New Hampshire. Last year, I 
created a nuclear safety unit in the attorney general's office be- 
cause it was clear to me that these issues demanded special re- 
sources and technical expertise if we were to meet the industry on 
level ground. I always expected the nuclear industry to be a formi- 
dable adversary but what I did not expect to find was the Nuclear 
Regulatory Commission intent on insulating itself from public par- 
ticipation and public process. 

In Seabrook we have seen it evidenced time and time again, but 
most recently and most blatantly in the Commission's decision to 
change the rules and attempt to knock Massachusetts out of the; li- 
censing process. And on that issue we'll meet the NRC in court. 
Here at Pilgrim, we see it again in the failure of the NRC to allow 
a full adjudicatory hearing on the many questions surrounding this 
troubled plant. Should the NRC reject the Commonwealth's pend- 
ing petition for enforcement action, then I'm prepared to take that 
issue to court. The NRC should require a full adjudicatory hearing 
on these issues. It has, after all, cited the plant repeatedly for its 
mechanical and safety and management problems. 

The issues that have brought you here tonight, the health impli- 
cations of restarting this plant are both real and deadly serious. 
We simply cannot allow this federal agency to continue its closed 
door deliberations on a matter of this magnitude. As Attorney Gen- 
eral I will use the full resources of my office to hold this utility and 
this Commission accountable to the people of the Commonwealth 
who deserve real answers obtained in a formal public hearing proc- 
ess. 

I know, Mr. Chairman, that you and the members of your com- 
mittee will continue to press the NRC for such a responsible public 
response. 



334 

I would also like to say, Senator Kennedy, that I'm deeply disap- 
pointed that the management of Boston Edison has refused to par- 
ticipate in tonight's hearing. They are in this room; they are sitting 
in the audience. If we are to trust them, they should be at least 
willing to come forward and state their case to you and to the 
people of this area. 

[Applause] 

Mr. Shannon. I think their management has been characterized 
by an ostrich-like quality for the last several years. They tell us 
things have changed. I think their failure to participate tonight 
raises serious questions as to whether we should trust them, and I 
hope that they will join us in requesting of the NRC a full process 
where they can make their case in a way that might restore confi- 
dence in management and leave the people of Massachusetts feel- 
ing that their health and safety will be adequately protected if Pil- 
grim is ever to go back on the line. 

[The prepared statement of Attorney General Shannon follows:] 



335 



TESTIMONY OF 
ATTORNEY GENERAL JAMES SHANNON 
BEFORE THE SENATE COMMITTEE ON LABOR AND HUMAN RESOURCES 

JANUARY 7, 1988 



Thank you, Senator Kennedy, for holding this hearing. The 
issue before you — the health implications of restarting the 
Pilgrim Nuclear Power Plant — is one of tremendous importance 
to everyone in the Commonwealth, but particularly to those 
people who are neighbors to this plant. I commend you, too, 
for coming here tonight so that the people who have been shut 
out of the process can finally be heard. 

The facts of this case have been well documented: 



-- The NRC currently ranks Pilgrim as one of the worst 
managed plants in the country. 

-- This past summer, the General Accounting Office 
reported that most of Pilgrim's management 
deficiencies remain uncorrected. 

— In 1982, the NRC fined Boston Edison $550,000 for 
submitting false information to the NRC and improperly 
operating Pilgrim. 

— By 1985, the utility had paid additional civil 
penalties totalling $90,000. 

— In fact, between 1983 and 1985, the NRC cited 
Pilgrim for 52 violations ranging from operations, to 
surveillance and raaiological controls. 

— Finally, in April 1986, Boston Edison shut Pilgrim 
down. 



These facts compel an open process, one in which Boston 
Edison will be required to prove its public claims that its 



336 



problems are solved. Instead, it appears the NRC intends to 
decide the fate of this plant on the basis of a closed 
inspection and evaluation. The people of the Commonwealth of 
Massachusetts deserve better than that. No one should consider 
reopening the Pilgrim Nuclear Power Plant until there has been 
a full adjudicatory hearing which clearly demonstrates that 
these problems have been solved. 

Senator Kennedy, both you and Congressman Studds have been 
forceful in calling for these hearings. The NRC's response 
that a public meeting be held is completely inadequate if we 
are to ensure public health and safety. 

In 1986, before my election as Attorney General, I was a 
petitioner calling for a full, adjudicatory hearing on the 
reopening of this plant. As Attorney General, I filed a second 
petition for the same, full legal proceeding. The NRC 
essentially rejected the first and has yet to act on the 
second. The private petitioners have appealed the NRC decision 
and my office is taking a lead role in that litigation. 

I continue to be deeply concerned not only about the 
threats this plant poses to public health and safety, but the 
unwillingness of both the utility and the NRC to address those 
serious issues in an open hearing. The NRC has a formal 
hearing process and they should use it if they expect to 
restore public confidence in this power plant. 

These two petitions are straightforward — they call for 

the NRC to hold a hearing in which Boston Edison must prove it 

can operate this plant safely and effectively. -- A hearing in 

-2- 



337 



which we can cross examine company and NRC experts and offer 
our own independent experts to review the facts. -- A hearing 
in which the NRC must issue a written decision which is subject 
to review in the courts. 

The public deserves a full hearing on the safety of this 
troubled nuclear plant. Boston Edison must be held to a burden 
of proof in an adjudicatory hearing to show that it can operate 
the plant safely something which it has yet to prove. 

Over the past year as Attorney General, I have been deeply 
involved in the very serious questions surrounding the 
regulation of the nuclear power industry both here at Pilgrim 
and through the licensing process of the Seabrook Plant in New 
Hampshire. Last year, I created a Nuclear Safety Unit in the 
Attorney General's office because it was clear to me that these 
issues aemanded special resources and technical expertise if we 
were to meet the industry on level ground. 

I always expected the nuclear industry to be a formidable 
adversary. But what I did not expect to find was a Nuclear 
Regulatory Commission intent on insulating itself from public 
participation and public process. In Seabrook, we've seen it 
evidenced time and time again, but most recently and most 
blatantly in the commission's decision to change the rules -- 
an attempt to knock Massachusetts out of the licensing 
process. And on that issue, we will meet the NRC in court. 

Here, at Pilgrim, we see it again in the failure of the NRC 



-3- 



338 



to allow a full adjudicatory hearing on the many questions 
surrounding this troubled plant. Should the NRC reject the 
Commonwealth's pending petition for a hearing, then I am 
prepared to take that issue to court. 

The NRC should require a full adjudicatory hearing on these 
issues. It has, after all, cited the plant repeatedly for its 
mechanical, safety and management problems. 

The issue that has brought you here tonight -- the health 
implications of restarting this plant -- are both real and 
deadly serious. We simply cannot allow this federal agency to 
continue its closed door deliberations on a matter of this 
magnitude. 

As Attorney General, I will use the full resources of my 
office to hold this utility and this commission accountable to 
the people of the Commonwealth who deserve real answers 
obtained in a formal public hearing process. I know, Mr. 
Chairman, that you and the members of your committee will 
continue to press the NRC for such a responsible, public 
response. 

Thank you. 



-4- 



339 

The Chairman. Thank you very much, Attorney General Shan- 
non. Let me ask you a few questions. Maybe you can review with 
us for just a few minutes, what the legal situation is relevant to 
the State of Massachusetts and the NRC, should the NRC plan to 
give approval for the start-up of Pilgrim I. What powers reside in 
you and the state to affect that decision? Maybe you could discuss 
that for us if you will. 

Mr. Shannon. I'll be happy to. As has been pointed out by previ- 
ous witnesses, there are really two petitions which have been filed, 
one which has been essentially rejected by the NRC. The Common- 
wealth is now involved as intervenor on appeal of that decision. 
The other one is 

The Chairman. What is that? 

Mr. Shannon. That is the petition which was put together by 
MASSPIRG included a number of members of the State legislature, 
myself, and Lieutenant Governor Murphy, and was filed during the 
summer of 1986. 

In the fall of 1987, I filed on behalf of Governor Dukakis and 
myself another petition, based on some of the old concerns that we 
had and some new ones which had been raised about this particu- 
lar reactor and which had come to light after the Barry report on 
evacuation planning. We're waiting for a decision from the Nuclear 
Regulatory Commission on that petition. 

If the NRC denies us a hearing after that process, then we'll take 
that matter to the Federal court, it is our right. There has been 
some suggestion that the Federal regulation completely preempts 
state officials from acting to protect the health and safety of the 
public; well, we don't accept that for a moment. I think that Gover- 
nor Dukakis, myself, other responsible state officials have implicit 
authority to act to protect the people of Massachusetts and we're 
willing to act to protect the people of Massachusetts, and we're 
willing to assert those arguments in court as well around the Pil- 
grim plant as we are around the Seabrook nuclear plants. 

The Chairman. You wouldn't draft the law the way it is now? 

Mr. Shannon. That's right, Senator. I think I would be a little 
clearer about where the Federal Government's authority ends and 
the States' begins. What is clear though, and I was in the Congress 
when that legislation was being debated, as were you, and what is 
clear is that in and post-Three Mile Island era. Congress intended 
for the States to play a very important role along with the Federal 
Government to actively protect their own citizens. 

As a matter of fact, the premise of all congressional action was 
that people could not be protected unless the states were included 
in that process. So I don't yield for a moment to the notion that we, 
the state officials, do not have the authority to act to protect people 
from the dangers of a poorly managed or poorly constructed power 
plant. 

The Chairman. I think that you should know that some of the 
NRC people are very adamant; they say that they'll be darned if 
they will let these nuclear powerplants be held hostage to the 
whims of the states. How do you react to that? 

Mr. Shannon. I've heard that suggestion from some people in 
the NRC. The notion that that we are acting arbitrarily and capri- 
ciously, particularly in this case, is just outrageous. 



340 

This is documented to be, by the NRC, one of the most poorly 
managed nuclear powerplants we have ever seen in the history of 
nuclear power. As late as just a few months ago, further deficien- 
cies were pointed out in the way in which the Pilgrim nuclear 
power plant has been run, by the Nuclear Regulatory Commission. 
They have fined Boston Edison in the past, and yet these deficien- 
cies have not been corrected. Serious questions have been raised 
about this reactor over the period of the last year, so the notion 
that we are acting at all arbitrarily or that this plant is being held 
hostage, is, I think, an affront, and I don't think that the people of 
the Commonwealth are going to buy that and I don't think people 
around the country will either. 

The Chairman. You are familiar with the MASSPIRG report on 
the economic implications of a permanent shutdown of Pilgrim? 

Mr. Shannon. I am. 

The Chairman. Then you know that they conclude that the utili- 
ty customers would actually save money if that happens; is that 
right? 

Mr. Shannon. That's right. 

The Chairman. Have any of your people in the attorney gener- 
al's office looked at that question? 

Mr. Shannon. Yes, Senator, we have looked at the MASSPIRG 
report. We do find it of real value as part of our evaluation. We are 
looking at the question of economics at Pilgrim right now. While I 
can't give you a definitive answer, I can say this. On the basis of 
the study we have done to date, we have concluded that at best. 
Pilgrim is now marginally economic. I think of the safety concerns 
apart from the economics because I don't think that there is any 
price we can put on the health and safety of the people who live in 
the areas around nuclear power plants. 

[Applause.] 

Mr. Shannon. But apart from the safety concerns that I've got, 
we must look at those economic questions and I think that when 
we look at them, we are going to find a lot of what MASSPIRG has 
said proves to be absolutely correct. 

The Chairman. Is it safe for me to assume that if a decision is to 
move ahead, that you are going to exercise all the rights as attor- 
ney general in every possible way to do everything that you possi- 
bly can to insure that that eventuality does not come about? 

Mr. Shannon. Senator, as you know and the people of the Com- 
monwealth know, we have been very actively involved over the last 
year in asserting, at every point we can, the rights of the people of 
the Commonwealth in protecting them against the Seabrook power 
plant. I want to say here tonight that I feel equally about the Pil- 
grim nuclear power plant. The Pilgrim nuclear power plant has 
the added disadvantage of a proven record of mismanagement on 
the part of the utility company which manages them, and I intend 
to fight just as hard to protect people around Pilgrim as we have 
around Seabrook. 

[Applause.] 

Mr. Shannon. Senator, I would like to ask that the petition filed 
by Governor Dukakis and myself be included in the record. 

[The petition referred to follows:] 



341 



UNITED STATES OF AMERICA 
BEFORE THE NUCLEAR REGULATORY COMMISSION 

PETITION OF MICHAEL S. DUKAKIS, GOVERNOR AND 
JAMES M. SHANNON, ATTORNEY GENERAL FOR THE 
INSTITUTION OF A PROCEEDING PURSUANT TO 
10 C.F.R S2.202 TO MODIFY, SUSPEND, OR 
REVOKE THE OPERATING LICENSE HELD BY 
THE BOSTON EDISON COMPANY FOR THE 
PILGRIM NUCLEAR STATION 



Dated: October 15, 1987 



342 



'i. ^; 



:-::^:j::::;-i 

zr.D-zMi :.- 3£.-^::'J5 A A:i \zz?.:\i o- f :::e-]c:;s 3 

iv. j/£R/:iV 3 

3. 3e::d'3 pas: pe?,- dr:ianc£ 4 

iEZ^'s 3A1? Evaluaf.ons 5 

3£:o'3 '.eg^laiDcy Viola': i op.s 

;. I'.zzz-.'.z ;:;^:::a o? 3ECo's ?E::^FOR'iA"iCE level .... 9 

SEZd's 193" 3A1? Report "- "' 

Rec3-:i Reoorto of Violations 2 

-/:je:ice iha: indizates thai .a plast specific 

= RA fZll-O.VED 3^: I'IPLEMENTATION OF AMY INDICATED 
SAFilr AZDlZ:Z\-:y.iS SHOJLD 3£ REQUIRED PRIDR 

:z p:'-3r:'V3 restart • • 1-2 

r _• - J -■ — r - r " ; i. J £ -J \ TE E'^ERGENCY PREPAREDNESS ... 15 



343 



aSFORS THE 'i'JCLz.\R RE^'JLATDRY 3 0«''! I 33 : 3>l 

PETinON DF MICH'VEL S. DUKAKIS, lOVER-jQR i,-;D 

JAMES '1. 3HANM0M, ATTORNEY GENERAL -OR "-{-. 

INSTITUTION OF A PROCEEDING PURSUANT TO 

10 C.r.R §2.202 TO MODIFY, SUSPEND, OR 

REVOKE THE OPERATING LICENSE HELD 3Y 

THE BOSTON EDISON COMPANY FOR THE 

PILGRIM NUCLEAR STATION 



I. INTRODUCTION 



Governor Michael 3. Dukakis and Attorney General 
JaTies M. Shannon, pursuant to 10 C.F.R. §2.206, hereby request 
that the Director of the Office of Nuclear Reactor Regulation 
institute a proceeding pursuant to 10 C.F.R. §2.202 to -nodify, 
suspend, or revoke the operating license ^Id oy 3oston "dison 
Co.-ipany ("3EC-." or "the Co-ipany" ) for t-e Pilgrim Nuclear 
Po^er Station '"PilgriTi") in Plynouth, Ma -sachuset t s . This 
petition is filed on behalf of the ConTionwea It h of 
Massachusetts and its citizens. The Governor and the Attorney 
General oase this request on evidence of continuing serious 
nanagerial deficiencies at the plant, on evidence that a clant 
specific prooabi list ic risk assessment ("PRA") as well as :-.e 
implementation of any safety modifications indicated thereby 
should be required prior to Pilgrim's restart, and on evidence 
that the state of emergency oreparedness does not orovide 
reasonaole assurance that adequate protective measure; can and 



344 



will be taken in the event of a raaiDloqical energenc/ i^ri-.^ 
operations at the Pilirm olant. The Governor and f'-e Xttor-.ev 
General submit that this evidence, as set forth oelow, 
demonstrates the necessity of Nuclear Regulatory Com-iission 
("NRC") action pursuant to 10 C.F.R. §2.202. 

Further, the Governor and the attorney General oelieve that 
the puDlic interest requires that the SRC exercise its 
authority under 10 C.F.R. §2.202(f)-^ so that SECo. is 
prevented from proceeding any further -^ith the restart of 
Pilgrim— until a formal adjudicatory hearing has been held 
and findings of fact are made concerning the safety questions 
surrounding the continued operation of the Pilgrim plant. In 
particular, the Governor and the attorney General request that 
the 'ARC issue an order, effective immedi = -ely, modifying 3SCo's 
operating license to preclude 3ECo. from -aking any steos m 



1/ 10 C.E.R. 2.02(f) provides: 

•Vhen the Executive Director for Operations/ 
during an emergency as determined ":>'/ the "00, or 
the Director of "luclear Reactor Regulation, 
Director of Nuclear Material Safety and 
Safeguards, Office of Inspections and 
Enforcement, as appropriate, finds that the 
public health, safety, or interest so requires 
or that the violation is willful, the order to 
show cause may provide, for stated reasons, tr.at 
the proposed action be temporarily effective 
pending further review. 

2/ At each step of BECo's so-called "power ascension" 
program there is an increase in the probability of an 
accident at Pilgrim as well as in the ootential 
consequences of such an accident. See Affidavit of 
Steven C. Sholly (attached hereto as Attachment 1). 



- 2 - 



345 



Its power ascer. 3.3r. pr^gra^n ^nt^l the hearing is nald and i-^. e 
findinqs are made. 

Recent events at Pilgri.'n indicate that 3'=:Co. has not 
corrected the lonq-standmg ^anaqerial shortcomings that have 
olagued the plant. In the areas of security, radiological 
controls, personnel management, and corporate culture, the 
-nanagement of Pilgri-n continues to be seriously flawed. ^s a 
result, Pilgrim poses an unreasonable risk to puolic health and 
safety. Its continued operation under the present ; 
circumstances is ni7\ical to puolic health and safety. 

^. 0VERVI3W 



PilgriTi commenced co.7.mercial operatio- in June, 1972, when 
3ECo. received an operating license for t-e plant. During the 
intervening fifteen year period of operation by 3SCo., Pilgrim 
has nad a capacity factor of approximately 50 percent, - 
which compares quite unfavorably with the average for all "ew 



England nuclear plants of approximately 67 percent. - 



4/ 



2/ The "caoacity factor" for a plant is a measure of 
oerformance" in terms of the power it has actually delivered 
over a period of time relative to the power it was caoaole of 
delivering over that same period of time. It is calculated by 
dividing the actual number of kilowatt hours oroduced oy the 
plant m the period of measurement by the product of the 
plant's rated" kilowatt capacity and the numoer of hours m the 
period. 

4/ Electric Council of New England, New England Nuclear News , 
fjune, 1937) (Attached hereto as Attachment 2) . 



346 



3. 3E.:-'3 PAST ?ERrO?>V'-: 



ilanc has 09en oat of service 



\pz.'., 19S6, w- 



the NRC, m Conf 1 nat ory Actior. letter 36-10, oraered a 
shutdown after rec_imng operational proble-^s at the pla-.t.- 
?ilqri.T> has been beset with managerial probleiis from tne 
outset. 3ECo. has consistently received low ratings m the 
VJac's Systematic Assessment of Licensee Performance ("SAL?") 
reoorts. Pilgrim has been identified by the 'JRC as one of t-.e 
worst run and least safe plants m the country- and 3ECo. 
was ordered to initiate performance/management improvement 
programs in 1982 and 1984.- 3ECo. has been the subject of a 
long line of enforcement actions as a result of regulatory 
violations. While the NRC's efforts to spur 3ECo. to a higher 
level of oerformance have, on occasion, met with some initial 
success, a review of 3ECo's performance -^cord, however, shows 
that all such successes have been short l.ved. Indeed, 3ECo. 



5/ Confirmatory \ction Letter 36-10 was clarified and expanded 
Tn an suosequent letter, dated August 27, 1937, from the MRC 
Region 1, Regional Administrator to 3ECo's Chief Operating 
Officer. (attached hereto as Attachment 3). In this letter, 
3SCo. was informed that: 

In light of the number and scope of the 
outstanding issues, I (the Regional 
Administrator) am not prepared to aporove 
restart of the Pilgrim facility until you 
(BECo.) provide a written report that documents 
3ECo's formal assessment of the readiness for 
restart operation. 

5/ 3oston Olobe, May 23, 1986. 

7/ Order 'lodifymg License Effective Immediately, 47 
Fed. Reg. 4171 (January 23, 1987). 



347 



appears co r.ave an organic inaoility to -nanage Pilgm 



a n 



effective and safe iianner.- 



3/ 



* * aRPn ' 



3ECo's S\LP Evaluations 



3ECo. has consistently received low ratings m SAL? 



9/ 
report s .- 



8/ Altho'jqh It IS the f 
Pilgrim plant which are 
significant that finding 
confirm 3ECo's manageria 
extend to the other aspe 
Edison Company , "^assachu 
Docket No. 87-lA-A (1987 
generating unit). Of pa 
3ECo. responds to the id 
half-hearted (although s 
solutions that treat the 
series of decisions by t 
Utilities that address 3 
sources of power in the 
the construction of the 
Company , MDPU 905 (1982) 
to meet its future power 
■.'Jo. 36-270 (found reason 
and/or skill to fulfill 



ailings of 3ECo's 
the subject of th 
s have been "nade 
1 deficiencies an 
ct s of Its busine 
setts Department 
) ( imprudence in 
rticuiar relevanc 
entification of d 
ometimes quite sh 

symptoms, not th 
he f^assachuset t s 
ECo's need to co-. 
aftermath of the 
Pilgrim II nuclea 

(ordering BECo. 

needs); Soston " 

to believe 3ECo 
public service ob 



management of the 
is pet It ion, it is 
in other settings tha 
d indicate that thev 
ss . See e.g. , 3os 



on 



of Public Utilities 
operation of oil fired 
e to the notion that 
eficiencies with 
owy) , short-term 
e disease, is the 
Department of Public 
■■-der and develop new 
.991 cancellation of 



3oston 



son 



' unit 

-. develop a new "plan 

iison C ompany , MDPU 



lacked commitment 
ligat ion) 



9/ The 3ALP process is the mechanism by which the NRC on a 
periodic oasis -systematically assesses the overall oerformance 
of a licensee. For each assessment period (generally 12 to 13 
months) a 3oard of NRC officials evaluates, in accordance with 
preestaolished attributes and rating guidance, the licensee's 
performance for each of the various, preest ablished functional 
areas and rates the licensee's performance m each area. The 
3oard also compares the licensee's performance for the current 
period with that of the previous assessment period and 
identifies, for further followup and inspection, any areas 
where the licensee's corrective action to improve oerformance 
has not been fully effective. 



Arizona Public Service Company , (Palo Verde Nuclear Generating 
Station, Unit 2), DD-86-8, 24 NRC 151, 156 (1986). 



348 



:n 135';, 3£Co. received ratings mdicacing sig* 



1 : .ca- 1 >je-.<'.iB3 



in three of the nine fanctional areas evaljated. The -lost 
recent SAL? Report, seven years later, indicates that 
conditions have not iTiproved but rather have vor~'ned. 3EC~. 
received ratings indicating significant weaknesses m five of 
the twelve fanctional areas evaluated. It has only once 
received a SALP Report without a rating indicating a 
significant weakness. On all other occasions, it has received 
reports indicating significant weaknesses in at least two 
functional areas. (See Appendix I: 3ECo. SALP History 
Tabulat ion ) 

Of particular significance, every time Quality Assurance 
has been assessed as a separate functional area during a SALP 
review, 3ECo. has received the lowest po.--ible rating. These 
findings are indicative of the inef f ect i /^ness of 3SCo's 
-nanaqeTient . They are a neasure of its i-.aoility and/or its 
lack of coTTiitTient to run the plant m a effective and safe 
■nanner. 

Although 3EC0. has at one tiie or anotner received the 
lowest possible rating in all but three of the twelve 
functional areas covered by the :)RC's SAL? process, these 
individual poor SAL? ratings are not the nost troubling asoect 
of 3ECo's SALP record. Instead, the -nost trouoling and telling 
facet of 3ECo's SAL? record is the Conpany's distinct inability 
to naintam any per iod-to-?eriod performance improvements. 
3ECo. has at one time or another improved its SALP oerformance 



- 6 



349 



in eignt fjnctionai areas. However, ic has not oeen ao'.e to 
sustain the increased level of performance m seven of t-ose 
eight areas. In all but one instance, 3ECo's I'^proved 
perforTiance proved to be short-lived and its oerf oriiance 
subsequently fell back to lower levels. This is not surprising 
as an ever recurring the-ne in MRC evaluations of 3ECo'3 

perfor'^ance is that NRC oversight and prompting is necessary at 

1 0/ 
every stage of Pilgrim's operation. — The increased NRC 

attention (i.e., oversight and prompting) that a "3" rating 

calls for has, on occasion, produced better performance bv 

3ECo. However, when that level of attention returns to that 

norm, 3ECo's performance falls below the norm. BECo's 3ALP 

track record is oroof of the proposition that BECo. by itself 

has not effectively operated Pilgrim and ' nat the short-term 

solutions It has adopted m response to :riticism have 

mvariaoly permitted the reoccurrence of ---.e original oroolems. 

** 3ECo's Regulatory Violations ** 

BSCo., an enforcement action record that is a mirror of its 
3\L? Report record. It has had at least one Severity Level III 
violation during each of the past six years. -=— ( See 



10/ 



, g., 1987 S.MP Review at 3; 1936 SAL? Review at 7, 



11/ \s set forth in 10 C.-.R. Part 2, Aipoendix C ; General 
Statementof Policy and Procedure for NRC Enforcement Actions, 
regulatory violations are categorized into five descending 
levels of severity. Level III corresponds with "violations 
tnat are cause for significant concern." 



- 7 - 



350 



\ODi:-.i:-< 



H2d. viol at: 3'J3 TAa'Jl.M'ION'S - SEVERITY LIV~1 



VIOLATIDNS ) In Che area d? Sec^niy aTd Safe^jar^s, 3"Co. -.ai 
a Severity Level III violation m all but one of fne years 
oetween 1931 and 1936. In 1932, a civil oenalty m tne a-nount 
of $550,000 -- at the tme the largest oenalty to have ever 
oeen assessed by the NRC -- was levied against ?ECo. for 
serious plant operations violations and for sabmitting false 
information to the NRC. — While the number of such Severity 
Level III violations discovered at Pilgrim has not exceeded two 
m any single year since 1981, the number of Severity Level IV 
violations per year has more than doubled in the past few years. 

BSCo's enforcement action record also mirrors its SALP 
Report record m demonstrating 3ECo's chronic recidivism. It 
nas been cited five times for Radiologic =•. 1 Controls violations 
involving vaste shipment packaging requirements. — 

It has oeen cited five times for Security and Safeguards 
violations involving the control of sensitive material such as 
<eys to vital areas, security plans, and firearms. — 



1_2/ U.S. General Accounting Office, Reoort to the Honorable 
Mfonse M. D'Amato, U.S. Senate: Maclear Regulation Efforts to 
Ensure N'uc^ear Power Plant Safety Can 3e Strengthened 
(3AD-RCED-a7-141 August, 1987), pp. 36-3''. 

13/ See NRC Enforcement Summary Tables taken from various SAL? 
Reports (attached nereto as Attachment 4). 

14/ Id. 



351 



c. ?;£C;.-.: ::;j:::a Or becd's =>:.-': j-^-'-/. ,z. ie/^i 



'he Tiost recent indicia o- 



level of 3lCd'3 oerfor-'a-.: 



m Tianaging Pilgrm are consisten': with its past oerf or'^anc? . 
They confirti the nocion that 9ECo. appears to oe orianically 
incapable of Tianaging a nuclear facility. Notwithstanding the 
frequent incantation by senior TianageTieht of a progra-n for t -.e 
"pursuit of excellence," the addition of new personnel and the 
expenditure of larg-? sums of Tioney, — the available evidence 
indicates that 3ECo. has not changed. Its 1987 SALP Report 
shows that the Company continues to merit the lowest possible 
ratings in many functional areas. 3ECo. continues to be 
incapable of maintaining performance gains. On the basis of 
news reoorts, it appears that 3ECo's management of the Security 
and Safeguards function is deteriorating, -ot improving, 
"urther, -n the basis of statements made ■/ NRC officials at a 
recent meeting, the :IRC has received and .s investigating 
allegations that the company may be compromising safety oy 
overworking its or its contractors' employees m an effort to 
return the olant to service soon. This evidence sumests that 
3ECo'3 claim to oe approaching readiness for restart may 



15/ E.q, 



NRC Docket ••10. 50-293, Offic 



Office of Nuclear Reactor Regulation, 
Edison Re: Pilgrim Status and ^ctivi 
Readiness," pp. 13-14, 13-20 (Septemb 
" 9/24/37 MRC/3EC0. Readiness Meeting " 
Steohen J. Sweeney, President and Chi 
3oston Edison Company, to the 'J . S . 4o 
Suocommittee on Energy Conversation a 
on Energy and Commerce July 16, 1986, 
as "Attachment 5" ) . 



iciai 
":iee 
ties 
er 24 
). .(T 
ef Ex 
use 
nd Po 



. ra 

t mg 
Lead 
,'l9 
est 1 
ecut 
f Re 
wer 
4-5 



n s c r 1 p 
W 1 1 n 
mg to 
3^) ( h 
mony S 
ive Of 
o resen 
of the 
( att ac 



t ot 
3osto 
Rest 
e *' e 1 n 

uomi t 



art 
after 
*■ ed bv 



i « 3 ^ , 



t a 1 1 V 

Comm 

h "* d h 



es. 

It t ee 
ereto 



9 - 



352 



16/ 



oe riast .■ and -nisleading. — 



** 3ECo'3 193'' 3MP Repo: 



On ^oril 3, 1987, the NRC released a S^LP Report for 3ECo. 
wnich was based on the results of various inspections and 
evaluations conducted at Pilgrim over the period from 
Novemoer 1, 1935 through January 31, 1987. Ratings were given 
for 3ECo's performance in twelve functional areas. In keeping 
with Its past record, 3ECo. received the lowest possible 

17/ 

ratings in five of the twelve functional areas. — it 
received the highest possible rating in only two functional 
areas.— ^ The picture painted in the SALP report is one of a 
plant witn "(p)oor management control," an "obscured ... chain 
of command and wea<ened accountability," ;nd " ( s ) signif icant 



recurring program weakness 



in some fu-.ctional areas, 
,.11/ 



showing the effect of ... long-term probleis. — 



16/ 3ECo's claim of readiness should be measured against its 
Idootion of 9/24/37 SRC/BECo. Readiness Meeting , o. 43. This 
tendency to ignore reality m the operation of the nlant nas 
been or«vously found to be undesiraole. See 3oston Edison 
Tomoany , MDP'J NO. 1009-F (1982) (3ECo. denied where evidence 
estaolished that it had imprudently underestimated the 
necessary time required to perform outage tasks). 

17/ The five areas were: Radiological Controls, Surveillance, 
Fire Protection, Security and Safeguards, and Assurance of 

Quality. 

13/ The two areas were: Outage Management, "Modifications, and 
Technical Support Activities and Engineering and Corporate 
Tecnnical Suoport. 

19/ 1987 SAL? REPORT at 3. 



10 - 



353 



Df part.cjlar i-iportance to this Petit. 01, were SM? 
ratings in three areas where =5ECo. hai previo^slv i-norovei .ts 
perf orTiance. in the fjnctional areas of Sa rvei I lance , ?ire 
Protection, and Licensing Activities, 3ECo. had m the oast 
iTiproved its ratings between periods -- m fire orotection, it 
had gone from a "3" to a "1" oetween its third and fourth SA'^P 
Reports — but by the tine of the review for the 1937 ShL? 
Report, Its perf oriiance had fallen back to earlier levels. 

With respect to the functional area of Security and 
Safeguards, the 1937 SALP Report discussed continuing hardware 
proolems, BECo's excessive reliance upon contractors, and 

TianageTient ' s failure to give this area sufficient 

20/ 
attention. — The report noted that BECo's corrective 

actions for deficiencies in this area hai not generally been 

effective and referenced three degradat lo-.s m vital area 

barriers that had occurred during the ev=.-jation neriod.— ^ 



20/ Id. at 31-34. 



21 / The CoTi-ii ssion' s regulations define a "vital area" as any 
area wnich contains: 



any equipnent 
failure, dest 
directly or 1 
and safety by 



'Stem, device 

ion, or rele 

rectly endang 



» sy 
ruct 
ndi r 
exoosure to radiation 



•material, the 
f w h 1 c n could 



f or 
ase 

er t he ouolic health 



or 



systems which 
protect publi 
failure, desc 
considered vi 
( 1 ) ( emphasis 
located withi 
to vital equi 
least two ohy 
§73.50(b) ( i) . 
be controlled 
author i2at ion 

to which barr 
"channel pers 
§73.45(0) ( 1) ( 



would be required to 
c health and safety f 
ruction, or release a 
tal areas. 10 C . F . R. 

added ) . Such areas 
n a protected area su 
pment requires passag 
sical barriers." 10 
Access into a prote 

through the checking 

and identity at entr 
lers surrounding the 
ons and material." 1 
1) and 73.50(c) . 

- 11 - 



qui p-ient 

function to 
ollowng such 
re also 

§■73. 2(h) and 
are to "be 
ch that access 
e through at 
C- .R. 
cted area is to 

of 
y cont rol ooint s 

protected area 
b C.F.R 



354 



** .Recent :^e ports of Vi^litnr. s ** 

On the basis of news reports and statements -lade oy ".^Z 
officials at a recent -neetinq, it appears that 3ECo. has 
suffered fron at least four significant Security and Safe^uarrs 
lapses m the past six months: a Tiisplaced lun; a misplaced 
set of sensitive -ceys; a "serious degradation in a vital area 
barrier;" and ineffective identification cards. — While all 
four alleged lapses would be significant, t.ne latter three 
would be a particularly strong indication of BECo's failure to 
learn from its past mistai^es -- nearly identical lapses have 
occurred in the past. — 

Further, allegations have recently been made which ^i^C 
stated at a recent meeting that they are investigating that 

3ECo. may oe compromising worker and/or c.ant safety by 

24/ 
requiring excessive overtime. — 

III. EVIDENCE VHW INDICATES THAT A PLANT SPECIFIC 

??^A FOLLOWED 3Y IMPLS-^ENT ATION OF ANY INDICATED 
SAFETY MODIFICATIONS SHOULD 3E REQUIRED I^O 
PILGRIM'S RESTART. 

Pilgrim is a GE Mark I design olant . As such, it has a 
primary containment which, by nearly unanimous agreement, has 
an extremely high probability of failure m the event of 



22/ Boston Glooe, Seotemoer 4, 1987, p. 1; 3oston Glooe, 
September 9, 1937, o. 21; 3oston Herald, September 10, i93 , 
p.' 24. 

23/ See 1985 SALP Reoort , o. 40; 1933 SAIP Reoort , op. 41-43, 
T982 SAL? Report , p. 38 (included in Attachment 3 hereto). 

I±/ Boston Globe, September 29, 1987, p. 21. 



12 - 



355 



certa.T a?r.3e-. ts. — '' This charac.erLStic is esper.allv 
critical since Mark I design reactors, such as ?ilgri-n, do not 
have the backup of a secondary contam-ient structure which can 
withstand any significant position pressure. ( "P'/^s" ) .2-i'^ i-, 
fact, Pilgrm's so-called "containment building" is not reallv 
designed to perform a backup function. It has "blow panels" 
which m some design and most severe accidents would activate 
and create a ready path for hazardous radioactive materials to 
escape into the environment. — The combination of an 
extremely vulnerable primary containment structure, a secondary 

containment not designed to provide an effective backup, and 

2 3/ 
the large population in the immediate vicinity of Pilgrim — 

compel the Governor and the Attorney General to request that 

the SRC modify the Pilgrim operating lice-^e to bar restart 

until a plant specific probabilistic ris' assessment ("PRA") is 

performed for Pilgrim and all indicated safety modifications 

are implemented. 'Jntil this occurs, the operation of the olant 

would oose an unreasonable threat to puolic health and 



; a r e t V 



29/ 



25 / See SUREG-1150, Reactor Risk Reference Document, Draft for 
Comment, Feb. 1987, at 4-33, 4-39. 

2_6/ Affidavit of Steven C. Sholly (attached hereto as 
Attachment 1 ) . 

22/ I_d. 

28/ Id. 
29/ Id. 



13 - 



356 



Tne w-ov-ernor an 3 the Attorney "er. eral are avare -'".a" :-. e 
M.RC has to date declined to order -^itigative -^odi f icat l o-:3 for 
.^ark I design plants. — They sab^iit, however, that the 
evidence presented here -- the comomation of extre-nely 
vulnerable cont ai ment structures and a larqe oopulation 
surrounding the plant -- precludes application of 'I'JREG- 11 50 ' s 
finding that the probaoility of a large reactor accident witn 
early fatalities is extre'nely remote. The 'rjREG-1150 findings 
do not reflect the amalgam of risks posed by Pilgrim. 

3E:co. has proposed a number of modifications as remedial 
actions for the plant's design def iciencies .— =■ These 
actions do not, however, address the inherent defects of the 
plant's design m any real -^ay. The Governor and the attorney 
General do, however, submit that through its so-called "safety 
enhancement program," 3SCo. has put the ~:9stion of the 
aooropriate modifications to be made to remedy the defects of 
the Mark I design in issue. 



30/ Z . g . , 3oston "dison Company (Pilgrim 'luclear Station), 
55-37-14, -IRC (1937) (slip at 31-32). 



31/ Letter with enclosures dated July 8, 193'', from 
Mr. Ralph G. =3icd, Senior Vice President-'^luc lear , Boston idisor 
Company, to Mr. Steven A. Varga, Director, "Division of Reactor 
Proiects, I/II, Nuclear Regulatory Commission (attached hereto 
as attachment 6 ) . 



14 



357 



;■ : D - ' 



)F 1)^\o-.j:mz EMiR^i--;:^ ?'^-i?\?zj-.-^s 



Withm the past twelve "nonfis, two authoritative 
assess::ient s have oeen made of the PLlgrim Radiological 
Sneraency Response Plan and the state of emergency preparedness 
within the Emergency Planning Zone ("EPZ") for Pilgrim. — 
3oth conclude that the plan and the state of preparedness "are 
not adequate to protect the health and safety of the public m 
the event of an accident at the Pilgrim 'luclear Power 
Station."—^ 3oth also concluded that the plan and the state 
of oreparedness have significant deficiencies and suggest 
Dotential remedies for those deficiencies that will require a 
substantial commitment of time, resources and 



coooerat ion 



34/ 



3EC0. has not quarreled with these 



conclusions.—^ The Governor and the Att::ney General submit 
that these conclusions compel immediate artion by the MRC. The 



32/ FEMA, "Seif-Initiated Review and Interim Finding for the 
pTlgrim Nuclear Power Station, Plymouth, y.\" (August 4, 193'') 
(hereinafter " FEMA Self -Ini t lated Review "); Secretary of Public 
Safety, "Report to the Governor on Emergency Preparedness for 
an Accident at the Pilgrim Nuclear Power Station" (Dece^.cer 16, 
1986) (hereinafter " 3arry Report " ) . 

33/ FEMA Self-Initiated Review at 1-2; 3arry Report at ''4. 

34 / FEMA Self-Initiated Review , pp. 12-13, 19, 22, 29-32, 
4 3-44; Barry Reoort , pp. 4 7-55. 

35/ 9/24/87 NRC/3EC0 Readiness Meeting", pp. 49-54. 



358 



36/ 
autr. :'---^--'^- exoer. agen r.es — agree tnat tnere 13 -. o 

reasonable assarar'.ce that the public :aT or will oe oroteoteo 

in the event of an accident at Pilgri-n. It is, thus, mcu-ce-.: 

jDon the NRC to take action mediately to insure that no-steos 

are taken by 3ECo. which could increase the likelihood or the 

3-7/ 
consequences of an accident. — 



\. THE PL^NNIMG ^ND PREPAREDNESS DEFICIENCIES IDENTIFIED 
3Y FSMA AND THE ?^ASS ACH'JSETTS EXECUTIVE OFFICE 
OF P'J3LIC SAFETY 



The deficiencies of the Radiological Enerqency Response 
Plans for Pilgrim are manifold. Although the analyses of FEMA 
and the Massachusetts Executive Office of Public Safety do not 
reach the same conclusions on all issues, the following areas 
of substantial deficiency have been ident.fied by both agencies: 

1. the lack of any articulated eva^iation plans 
for oublic and private schools =.3 well as day 
carecenters; 

2. the lack of any articulated evacuation plans 
for the special needs population; 



16/ 
exne 

of fs 
Fed. 
IS e 
emer 
10 C 
Safe 
Offi 
§1 I 



FE^A 13 explicitly recognized by the Com-nission as 
rt Federal authority on questions of nuclear power 
.^o oTiergency preparedness (Memorandum of 'Jnderstan 
'Reg", No. 75, 15,486 (April 18, 1985) and the Comm 
xoressly required to base its findings on off-site 
gency issues on FEMA's conclusions concerning sucn 
.F.R. §50.47{ s) ( 3) . The Massachusetts Secretary of 
ty'oversees the Ma - lachusetts Civil Defense Agency 
ce of Emergency Planning, which pursuant to M.g.l. 
s resoonsiole for the Commonwealth's emergency acti 



1 s 

? 

an 



he 
ant 

ng, 5 
SI on 

sues . 
u b 1 1 c 
d 

147, 
ties. 



2''/ -ach s-ep of 3ECo's oower ascension plan corresoond'; with 
"substantial" increase in" the probability of an accident at 
Pilgrim. Affidavit of Steven C. Sholly (attached hereto as 
Attachment 1 ) . 



16 - 



359 



-. ". ^ L a r ■-. 1 a -. / a r t . ; j . a -. e i 3 / a ? ^ :i - . o -. t - a -. ^ 
foe tne tran spor': iepen den. popjlaiiop. ; 



4. tne lack of iiientifraol'? paolic .^helier 
the oeacn oooul a" lor. ; 



to: 



5. tie laci^ of a rsception cen.er, as requir'?i 
n tne plan, for people evacuatiiq by the 
nortnern route; 

5. the lacK of real progress m plannnq and the 
dminijtion ;n tne state of eTiergency 
prepa redness .13.' 

These are critical deficiencies. The olans do not e.ven 

ourport to provide any -neasure of protection for significant 

namoers of people: pre-school and school age children; f'ose 

-vno require special measures to transport; and those without 

read/ access to private transportation. They fail to address 

tne significant oeach population in an adequate fashion. Thev 

do not incorporate current or reliable evaluation tine 

estimates ("ETEIs"). Jor io they mcorpor -. -.e a delineated 

inventory of identified and identifiable Telters which are 

accessiole to tne public. Moreover an integral co-^po-ent of 

39/ 

zr.e current plans -- a nortnern receotion center — . 



J_3/ FZ'^A 3e If -Initiative Review , -pp. 12-13, 19, 22, 29-32, 
4 3-4 4; 3arry Report, pp. 4 7-5 5. 



11/ 
nort 

Tne 

evac 

m 1 

recs 

woul 

desc 

woul 

~oni 

i^ev 1 



The lack of a reception center for 
h is as worrisone as tne .Tiore genera 
lacK of a northern reception center 
uation from the Z?Z were successful 
ight of tne assorted planning defici 
ived and followed instructions to ev 
facilities availaole at th 
\ccording to F^'.W, aoproxi 
witnou- facilities at whic 
decontaminated if necessar 



d find no 
1 n a 1 1 n . 
d oe left 
tored and 
e w at 19. 



those 
1 Ola 
1 n d 1 c 
-- a 

a ^ f ■ o 

acuat 
eir i 

mat el 
h to 
■/• I 



eva 

ates 

s -- 
e to 
es la 
y 60 
r eg i 



c u a 1 1 

g fai 

t n a - 

1 c as 
thos 
the 
nated 
,0 00 
ster , 
Self- 



ng to 
1 ires , 

3 '/ a n 

3 U -^ O t 

e who 
north 

p e o o 1 ■ 
oe 



ion 



ated 



17 



360 



-- :3 ^ IS i-.'.z a.t^aetr.er. rmaiLy, orrs.te exerr.sea ar-. :: 
drills -- the most effective "neans of assari^.q o reoa rei-.es 3 
nave not been held m years. 



3. the: c'Jsssmt status of planning and preparedness 



The specific functional deficiencies m the first four 
areas enunerated above, as well as the functional areas m 
which work .Tiust be done before any det er-nmat ion can be -nade if 
adequate plans can be developed, encompass the entire set of 
tasks required for adequate planning and preparedness: 
1. Identification/EstiTiation of populations; 
Identification/Estimation of resources; 



2. 

3. 



Develop plans for emergency actions to be 
tai^en for each population with potentially 
available resources; 



4. Obtain commitments for require: resources; 

5. Provide education/information "o public; 

6. Conduct exercises/drills . 

At oresent, it apoears that the school/daycare oooulation 

nas oeen identified but that the special needs and transport 

4 "I / , 
deoendent populations have not .— ^ Preliminary estimates o. 

the resources potentially available to evacuate these 

populations have now oeen obtained, but neither plan 

development nor obtai-.-ng commitments of resource availability 



41 / 



can orocee 



ed m the absence of reliable ETEs. — 



£0/ Executive Summary of the Reaort on E-ergencv Prepa redness 
ror an Accident at Pilgrim Power Station ) (October 15, 193'') 
Thereinafter "3arry Report Update"), p. 2. 

41/ Id. 'at 2. 



- 13 - 



361 



While 3r:co. has recently -- ^jgast 13, 193^ -- del.;erei an 
ETE stady to the Commonwealth's puoiic safety officials,— 
the document is still oeing reviewed by those officials a-,i 
preliTiinary analysis has uncovered shortcomings that will 
necessitate further work. It is, thus, unlikely that final 

ETEs will be available withm the irimediate future for use m 

4 3/ 
developing specific plans. — This shortcoming is critical. 

A consequence of the unavailability of reliable ETEs is that 

emergency planning is effectively on hold. Even when the ta3< 

of identifying/estimating populations and resources is 

completed, radiological emergency planning cannot in any real 

sense proceed without reliable ETEs and a traffic management 

plan. ^s FEMA and the NRC well recognize, a realistic set of 

ETEs is an essential element of a workaol^ emergency plan. See 

Cincinnatti Gas 5. Electric Company (Wm. -: . Zimner Nuclear Power 

Station, Unit No. 1), ALA9-727, 17 NRC 76:, 770-71 (1983). 

With respect to the beach population, orelimmary 

population estimates and sheltering data have oeen provided to 

the Commonwealth's public safety officials out, at least m the 

case of the sheltering survey, these materials have oeen found 



4 2/ KLD Associates, Pilgrim Station Evacuation Time Estiiates 
and Traffic Management Plan "Jodate (Final Draft for Review) 
August 18, 1987. 

43 / 3arry Reoort Uodate , p. 2. 



- 19 - 



362 



4 4/' 
Z3 se .". a::-ej_:i-_e fjc plan ". .-. g p^rpDses. — ^' 

\5a1r:, plan develop^er.z and resojrie avai'-aoili*:/ co-^^it"?-. •: 

■njcp. less public ed jcat ion/ in.f or-nai ion efforts and 

exercises /drills, cannot proceed asefully wit ho at reliaole 

43/ 
final EIEs and sheltering data. — 

.Jo replacement site for a northern reception center has 

46/ 
oeen found — and no detemmation has yet been made whet he: 

an emergency plan incorporating only two reception centers 

47/ 
would provide an aaequate assurance of protection. — 



44 / 3arry Report Update , p. 2; Letter with enclosures from 
Rooert J. 3oulay, Director, Massachusetts Civil Defense ^gencv, 
dated Sepcemoer 13, 1937, to Ralph C. 3ird, Executive Vice 
President-Nuclear, Boston Edison Company (attached hereto as 
Attacnment 7 ) 



45 / 3arry Report Jpdate , p . 2 ; See also -- 'A Self-Init: 

Review at 26-27: 

3efore FEMA and the RAC can make a -.eterminat ion 
on tnis (whetner protective actions ^or thebeach 
population are or readily can be made adequate) 
It must receive the following infornation: 



1) 

beac 

anal 

numo 

the 

geog 

of t 

Che 

bull 

popu 

capa 

dist 

are 

clea 

and 

aoor 



an J 

nes 

ysis 

er o 

numo 

raph 

ne 1 

oeac 

ding 

lati 

citi 

ance 

not 

ciy 

lett 
oor 1 



pda 
and 

of 

f ? 
er 
ica 
eng 
h p 
s a 
on 
es 
s f 
ope 
st a 
e r s 
ate 



ted 
tne 
the 
erma 
of d 
1 di 
th o 
opul 
vail 
at e 
of t 
rom 
n CO 
te h 
of 



geog 
ir c 

oea 
nent 
ay V 
sper 
f ti 
at 10 
aole 
ach 
hese 
tne 

the 
ow t 
a::re 



raphical 
apacity ; 
ch popula 

and temo 
isi tors , 
SI on; 3 ) 
me It wou 
n ; and 4 ) 

for shel 
beach, m 

bui Iding 
beaches . 

public, 
hey will 
ement mus 



d '^ s c 
2) 

t ion 
orar 
toge 

an 
Id t 

a 1 
ten 
clud 
s an 

If 

be m 
t oe 



r ipt 10 
a deta 
, mcl 
V r e ^ 1 
the: w 
update 
ake t :> 
ist of 
ng tne 
inq th 
d t nei 
these 
plans 
ade ac 
obt ai 



n 

lied 

jdin 

dent 

1 th 

d es 

eva 

sui 

oea 



« t- ha 



q -- 

s a 
the 
t im 
cua 
tab 
ch 



he 
nd 

ate 



oui i 
must 
cess 
ned 



cmgs 

lole 
as 



46/ 



see 



42/ 9/24 MRC/3EC0. Readiness Meeting , p. 52. 3u' 
FEMA Seif-Init lated Review at 19 (The use of only two 



reception centers 
feasiole.") . 



IS not likely to be logistically 
- 20 - 



363 



r : n a ". 1 / , i -. i r. e a d s e n r ? of -. e w plans, ? ^ o I ■_ c 
mf or.Tiacion/educaci on efforts and exer ci ses/ir : 1 1 3 canno-:, -.v 
jefmition, occur. There are no plans to •.nfor-n -.he ouo".:? -;- 
exercises, Tiacn less to exercise. Although the provisions 0" 
10 C.r.i^. Part 50, Appendix S, Section IV.F. require that a 
full participation oiennial emergency oreparedness exercise -or 
Piigrm oe neld this year, the MRC is presently considerim a 
request from 3£Co. for a one-tme exemption from that 
requirement to allow the exercise to be postponed to the second 
quarter of 1988.—'' 

17. COriCLJSIDN 

In light of all of the foregoing deficiencies of the 
current state of e^nergency planning and preparedness, as veil 
as tne suostantial questions raised herei- roncerninq the 
managerial aoility of the licensee, 3ECo., and the safety of 
the Pilgrim reactor, the Governor and Attorney General submit 
that the :JSC must take action pursuant to 10 C. F . ' . <;2.202 to 
insure tnat 3SCo. does not take any action tnat could increase 
eitner the ris< or the consequences of an arcident at PilTri". 

Since tnat Pilgrim is a 3S "larK I design reactor, and the 
£?Z population at tnis plant is among the nighest m the 
country, it is evident that the deficiencies m emergenrv 
planning and preparedness are significant for Pilgrim. These 



43 / Letter ^itn enclosures dated Septemcer 13, 1937, from 

Mr. Ralph G. 3ird, Senior Vice President-Nuclear, Boston "diso- 

Company, to :IRC (attacned hereto as Attachment 3). 



21 



364 



jgf_j.-;-. r.es are so suos-antial and t'-.eir poteitial 
ratifications are 3D significant, tl^a': it is i-npossiol? to 
conclade that any interim compensating actions have or can oe 
ta<en. T"-.e :JRC' s regulations leave it no course other than 
issuing an order modifying 3ECo's license to extend the curre- 
shut down pending the outcome of a full hearing on the 

significant outstanding safety issue- and the development and 

•' 4 9/ 

certification oy the Governor of adequate emergency plans. — 

Respectively submitted, 



James M. Shannon 
Attorney General 
Commonwealth of *1assachuset t s 



Michael S. Dukakis 

Governor 

Commonwealth -f "Massachusetts 

■Dated: Octocer .5, 1937 



4 9/ Compare n C.r.S. §50.54(s)(2)(ii): 

... In determining whether a shutdown or other 
enforcement action is appropriate, the Commission 
3r-.all take into account, among other factors, 
■,,-a-ner the licensee can demonstrate to the 
:o--i33ion'3 satisfaction that the deficiencies 
m t ne olan are not significant for the plant m 
question, or that adequate interim compensating 
actions have been or will be taken oromotly, or 
that there are other comoelling reasons for 
continued operation. 



- 22 - 



365 



APPENDIX I: BECo. Sa,L? HISTORY T'lB'JLATIOM 



Inspec . 
Period 


Plant 
Oper . 

2 


Radiol . 
Control 

3 


Maint . 


Sarveil . 


Fire 
Prot. 

2 


£ Tie toe ". . 
P r e D a r e -i 


01/01/80 
12/31/30 


2 


2 




2 


09/01/80 
08/31/81 


3 


2 




3 


2 




2 


1 


09/01/31 
06/30/82 


3 


2 




2 


2 




3 


1 


07/01/32 
06/30/83 


2 


2 




2 


1 




1 


1 


07/01/83 
09/30/84 


2 


3 




1 


1 




2 


3 


10/01/84 
10/31/85 


3 


3 




2 


2 




- 


3 


11/01/85 
01/31/87 


2 


3 




2 


] 




3 


2 


I ".spec. 
Period 


Secur . 
Saf egds 


Out. 
Mod. 


Mqt . 
Act 


Licen. 
Activ, 


Eng/C 
Tech. 


:orp 
Sup 


Train 
Qual .Ef 


Quality 
A s s u r a n 


01/01/30 
12/31/80 


2 


3 




- 


- 




- 


3 


09/01/80 
03/31/31 


2 


2 




- 


- 




— 


3 


09/01/31 
06/30/32 


2 


2 




2 


- 




— 


~ 


07/01/82 
06/30/33 


2 


- 




1 


- 




- 


"" 


07/01/83 
09/30/84 


2 


1 




1 


- 




— 


~ 


10/01/34 
10/31/35 


2 


1 




1 


- 




— 


"• 


11/01/35 
01/31/37 


3 


1 




2 


1 




2 


3 



i 



366 



APPE^4DIX II: 3ECo. VIOLATIONS TABULATIONS 



SEVERITY LEVEL III VIOLATIOHS: 9/1/81-1/31/37 
Functional Area 1981 1982 1983 1984 1985 198( 



.33' 



?lant Operations 
Radiological Controls 
Mainenance 
Sar vei 1 lance 
rire Protection 
Emergency Preparedness 
Security/Safeguards 
Outage Mgt . . . 
Licensing Activities 
Training ... Eff ness 
Assurance of Quality 
Engineer/Corp. Support 



Severity Level 



3ECo. VIOLATIOMS 3Y SEVERITY LEVEL: 9/1/81-1/31/87 
31/32 82/33 33/84 34/35 85/87 



I 












II 












in 


7 


1 


1 


2 


1 


IV 


9 


9 


13 


17 


21 


V 


20 


20 


6 


5 


6 


VI 


2 










Deviations 


2 


3 


I 


3 


1 


Total Violations 


40 


33 


26 


27 


29 



367 



UNITED STATES OF AMERICA 
NUCLEAR REGULATORY COMMISSION 



BEFORE THE COMMISSION 



In the matter of 

BOSTON EDISON COMPANY 

(Pilgrim Nuclear Power Station, Unit 1) 



Docket No. 50-293 



AFFIDAVIT OF STEVEN C. SHOLLY 



Steven C. Sholly, being on oath, deposes and says as follows: 

I am an Associate Consultant with MHB Technical Associates, 1723 Hamilton 
Avenue, Suite K, San Jose, California, 95125. A statement of my professional 
qualifications is attached hereto and marked Attachment A . In brief, I have 
more than six years experience in the review, analysis, interpretation, and 
application of probabilistic risk assessment to the analysis of safety issues 
related to commercial nuclear power plants, including issues related to 
radiological emergency planning. I have served as a member of the peer 
review group for the NRC publication NUREG-1050 (1984) ^Probabilistic Risk 
Assessment rPRA) Reference Document . September 1984), and have more 
recently sen/ed as a member of the Containment Perform ance Design 
Objective Workshop , the Panel on ACRS Effectiveness (1985), and the Sei^ere 
Accident Policy Implementation External Events Workshop (1987). I have 
previously testified as an expert witness on probabilistic risk assessment and 
emergency planning matters in NRC proceedings on the Catawba Units 1 and 
2, Indian Point Units 2 and 3, and Shoreham Unit 1 nuclear plants, and also m 
the Public Inquiry regarding the proposed Sizewell-B nuclear plant in the United 
Kingdom In addition, I have co-authored two major reviews of source term 



368 



-2- 



and risk estimate issues published in NRC reports NUREG-0956 and NUREG- 
1150. I have also performed reviews of various technical aspects of the 
Shoreham, Limerick, Indian Point, Sizewell, Zion, Seabrook, Millstone-3, and 
Oconee-3 probabilistic risk assessments and the Vermont Yankee 
Containment Safety Study. 

f^HB Technical Associates ("MHB") has been requested by the Nuclear Safety 
Division, Department of the Attorney General, The Commonwealth of 
fj/lassachusetts, to evaluate the increase in risk resulting from a startup 
program for return to power from the current refueling and modifications 
outage for the Pilghm Nuclear Pov\er Station, Unit i (PNPS-i). 

In its current configuration (refueled) and considering the duration of the 
current shutdown, Pilgrim currently poses very little i- -k to the public health and 
safety. This is due to the multiplicity of systems theoretically available to inject 
water into the reactor vessel and due to the low decay heat level present in the 
fuel. In the event of a core heatup transient with the plant in its current 
configuration, considerable time would elapse between initiation of coolant loss 
and the onset of fuel damage, time during which measures could be taken to 
initiate coolant makeup and/or other recovery and mitigative actions. 
Moreover, in theory a longer time period is available within which to implement 
offsite protective actions due to the slower accident progression time 
compared with accidents at higher power levels. 

Boston Edison Company (BECO), the licensee for Pilgrim, currently envisions 
restart power ascension program with a minimal number of hold points. In 
brief, BECO proposes to institute holds on restart (pending approval from NRC 
in accord with Confirmatory Action Letter No. 86-10), recovery from reactor 
mode switch testing prior to conducting a test for shutdown from outside the 
control room, and prior to movement of the scram set point above 95% power. 
[Sgfi, Boston Edison Company, Pilgrim Nuclear Power Station Re start Plan. 
pages IV-29 to IV-31.] The details of the power ascension program in 
Attachment 13 of the Pilgrim Nuclear Power Station Restart Plan have not yet 
been provided. 



369 



My current understanding of the BECO power ascension program is that the 
program would result in a relatively rapid ascension from the current shutdown 
condition to full-power operation. In so doing, the risk to the public health and 
safety posed by operations at the Pilgrim plant will be increased markedly. 

The Commission has concluded generally that the risks from 5% power 
operation are negligible. [ See , for example, SECY-84-155, 12 April 1984, and 
attachments; and letter dated 15 June 1984 from Nunzio J. Palladino to Hon 
Edward J. Markey, and attachments.] The evaluations upon which the 
Commission has drawn these conclusions, however, were for plants with very 
little operating history and no spent fuel pool inventory. Clearly, Pilgrim is 
different in this regard, with a substantial long-half-life fission product inventory 
present m both the refueled reactor core and the spent fuel pool. Moreover, 
these evaluations did not consider the unique risks posed by accidents 
resulting from externally-initiated events (specifically, in this case, seismic 
events). In my opinion, the presence of more than 1 100 spent fuel assemblies, 
prior operation of two-thirds of the core at equivalent full power for most of an 
operating cycle, and the matter of external events render the circumstances at 
Pilgrim sufficiently different from those previously evaluated for 5% power 
operation that the previous evaluations understate, perhaps significantly, the 
risk posed by operation of Pilghm at 5% of full power. This conclusion is 
further supported by the likelihood that the primary containment will not be 
inerted until operation above 5% power is commenced. In my opinion, virtually 
any severe accident at 5% power with the containment de-inerted will result in 
early containment failure (due to hydrogen burn or hydrogen detonation m the 
primary containment, and/or other causes). 

As power level increases, risk to the public increases. This is due to several 
factors, including a marked increase in volatile fission product inventory and a 
marked increase in decay heat level, which results in accident progression 
times which are much shorter than at low power levels. This reduces the 
amount of time available for implementation of recovery and/or mitigation 



370 



-4- 



actions and reduces the amount of time available to implement offsite 
protective measures. 

A full-scope probabilistic risk assessment for the Pilgrim plant has been in 
progress for several years. It is my understanding that this study is nearly 
completed. It is my expectation that this study will identify seismic initiating 
events as a significant contributor to core melt frequency (i.e., contributing 10% 
or more to core melt frequency from all causes). This expectation is based on 
my familiarity with seismic risk assessments performed on similar designs and 
performed on other plants in the general region of Pilgnm (e.g., Shoreham, 
Seabrook Units 1 and 2, f^illstone Unit 3, and Limerick Units 1 and 2). 
Seismically-initiated accident sequences are accompanied by potentially 
severe impacts on offsite emergency response even when there are fully- 
approved and operational emergency plans. In the case of Pilgrim, the current 
status of emergency planning is such that there is not adequate assurance that 
protective actions can and will be taken in the event of an accident. Given the 
more severe conditions of a seismically-initiated accident scenario, this 
conclusion is all the more applicable. 

A study of risk at 25% power for the Shoreham nuclear plant, which possesses 
a nuclear steam supply system which is grossly similar to Pilgrim, Indicates that 
the core melt frequency for operations at up to 25% of full power may not differ 
dramatically from the core melt frequency at full power. The 25% power PRA 
estimates a core melt frequency of 2.8 x 10'^ per reactor-year. [ See . E.T. 
Burns, S. Mays, and T. Mairs, Probabilistic Risk Assessment of the Shoreham 
Nuclear Power Station: Initial Power Operation Limited to 25% of Full Power . 
Delian Corporation, prepared for Long Island Lighting Company, April 1987, 
page 4-12.] The full power PRA analyses for Shoreham estimated a core melt 
frequency of about 6.5 x 10'^ per reactor-year. [ See . Science Applications, 
Inc., Final Report: Probabilistic Risk Assessment. Shoreham Nuclear Power 
Station , prepared for Long Island Lighting Company, 24 June 1983, page 4; 
and V. Joksimovich, et al., Maior Common-Cause Initiating Events Study: 
Shoreham Nuclear Power Station . NUS Corporation, NUS Report No. NUS- 
4617, prepared for Long Island Lighting Company, February 1985, page 1-8] 



371 



This represents less than a factor of three difference in the likelihood of a core 
melt accident at 25% power versus full power. Although this assessment is for 
Shoreham and not for Pilgrim, it suggests that the likelihood of an accident is 
not markedly different for 25% power versus 100% power. 

10. Further, a limited-scope PRA of Shoreham at 5% power was prepared for 
LILCO. This study, which did not include external events, concluded that the 
core melt frequency for 5% power operation was about 4.9 x 10'^ per reactor- 
year. [ See . Delian Corporation and Science Applications, Inc., Probabilistic 
Risk Assessment. Shoreham Nuclear Power Station. Low Power Operation Up 
to 5% of Full Power , prepared for Long Island Lighting Company, draft, May 
1984, page 78.] This indicates that core melt frequency at 5% power is 
significantly reduced from 25% power or full power, by a factor of roughly 20, 
but not nearly as significantly reduced as previously predicted by the NRC staff, 
which predicted a reduction factor of 1 ,000 or more. 1/ Moreover, the 5% 
power reduction factor of 20 is an underestimate since the 5% power estimates 
do not include external events. 

11. The 5%, 25%, and 100% power PRA studies for Shoreham indicate, in my 
opinion, that the core power level for Pilgrim will have at best a moderate 
impact on the likelihood of an accident. Considering the uncertainties involved, 
the likelihood of an accident may be nearly indistinguishable at the various 
power levels indicated above. Moreover, the Shoreham results are lower than 
the core melt frequency estimates for many other plants. A Brookhaven 
National Laboratory review of the Shoreham PRA for internal events only 
estimated a core melt frequency of 1 x 10"* per reactor-year. An average value 
for full-scope PRAs completed to date is of the order of 3 x 10"* per reactor- 
year. 



1/ The NRC staff, in SECY-84-156, predicted core melt frequency reduction factors 
for various classes of BWR accidents ranging from 1,000 to 100,000. [See, 
SECY-84-1 56. Enclosure 1 , "Staff Review Process for 5 Percent Power Operation", 
page 2.] Thus, in the aggregate, the NRC staff would have expected a core melt 
frequency reduction of at least 1,000, compared with the Shoreham value of 20. 
The results for Shoreham indicate a reduction factor approximately 50 times less 
than the NRC staff expected based on engineenng judgment. 



372 



12, These results are especially significant for a plant with a containment design 
similar to Pilgnm. Pilgrim employs a steel Mark I pressure suppression 
containment. Such containments have been estimated m a variety of studies 
sponsored by IDCOR, NRC, and utilities to have an early containment failure 
probability -- given a severe accident -- in a range from 10-90%. This means 
that there is a significant chance that, given a severe accident, the accident will 
be accompanied by a large early release of radioactivity to the environment. 

13. The Pilgrim plant, like all tVlark I containment design plants, also employs a 
secondary containment, usually referred to as a reactor building. This 
structure is not designed to withstand the high internal pressures which would 
accompany a severe accident, and is unlikely to survive in a leak-tight condition 
following primary containment failure. High pressure in the secondary 
containment due to a severe accident would be produced by a combination of 
blowdown due to primary containment failure, primary containment leakage, 
phmary containment venting, and burning of combustible gases. Indeed, Mark 
I plants are designed with both internal and external "blow-out panels" which 
are designed to relieve pressure. In the case of Pilgrim, there are blow-out 
panels at the refueling deck elevation which relieve pressure directly to the 
environment. In my opinion, there is little basis for assuming that releases from 
the primary containment will be significantly mitigated by the presence of the 
secondary containment. 

13 Based on the above considerations, it is my opinion that Pilgrim Unit 1 should 

not be restarted until the offsite emergency response plans are upgraded and 
evaluated to adequately protect the public health and safety. Further, it is my 
recommendation that BECO be required to promptly submit the Pilgrim 
probabilistic risk assessment study to the NRC for public review and evaluation 
prior to restart. The review of such a study should indicate whether there 



373 



-7- 



remain significant operational risks which must be amelioriated in order to 
provide adequate protection to the public health and safety, 





Steven C Sholly 
Associate Consultant 




GENERAL ACKNOWLEDGMENT 



State ot_ 



County ot 



t Ji Z,-.-.,^ ^ 



On this the 



^^ day 01 (\2^^ZZZ^^ 



'9£z oetore f^e 



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OFFICIAL SEAL 

MrUNA L BARRY 

NOTARY PU8UC • CAUFOBNIA 

3Mir« cum couirrr 

My lTtT*(l §ipir«s )UW 



the undersigned Notary Public aersonally appeared > 



personally <nown to me 
•^proved to me on the Basis of satisfactory evidence 

to De the personisi whose nameisi / J sutiscnped to the 

within instrument and acknowledged that h <; pxprnipn it 

WITNESS my hand and official seal 




NATIONAL NOTAOY »SS0CI«TI0S . J 301 J Ve^lu'a 81.0 . OQ Bo. 4625 ■ Aoooanfl -.«» CA m,ili . 



374 



ATTACHMENT A 



PROFESSIONAL QUALIFICATIONS OF STEVEN C. SHOLLY 



STEVEN C. SHOLLY 

MHB Technical Associates 

1723 Hamilton Avenue 

Suite K 

San Jose, California 95125 

(408) 266-2716 



EXPERIENCE 



September 1985 - PRESENT 

Associate - MHB Technical Associates, San Jose, California 

Associate in energy consulting firm that specializes in technical and 
economic assessments of energy production facilities, especially nuclear, 
for local, state, and federal governments and private organizations. MHB 
is extensively involved in regulatory proceedings and the preparation of 
studies and reports. Conduct research, write reports, participate in 
discc'ery process in regulatory proceedings, develop testimony and other 
documents for regulatory proceedings, and respond to client inquiries. 
Clients have included: State of California, State of New York, State of 
II 1 inois. 

February 1981 - September 1985 

Technical Research Associate and Risk Analyst - Union of Concerned Scien- 
tists, Washington. D.C. 

Research associate and risk analyst for public interest group based in 
Cambridge, Massachusetts, that specializes in examining the impact of ad- 
vanced technologies on society, principally in the areas of arms control 
and energy. Technical work focused on nuclear power plant safety, with 
emphasis on probabilistic risk assessment, radiological emergency 
planning and preparedness, and generic safety issues. Conducted 
research, prepared reports and studies, participated in administrative 
proceedings before the U.S. Nuclear Regulatory Commission, developed 
testimony, aniayzed NRG rule-making proposals and draft reports and 
prepared conments thereon, and responded to inquiries from sponsors, the 
general public, and the media. Participated as a member of the Panel on 
ACRS Effectiveness (1985), the Panel on Regulatory Uses of Probabilistic 
Risk Assessment (Peer Review of NUREG-1050; 1984), Invited Observer to 
NRC Peer Review meetings on the source term reassessment (BMI-2104; 1983- 
1984), and the Independent Advi-sory Connittee on Nuclear Risk for the 
Nuclear Risk Task Force of the National Association of Insurance 
Commissioners (1984). 



-1- 



375 



January 1980 - January 1981 

Project Director and Research Coordinator - Three Mile Island Pub l ic 
Interest Resource Center, Harrisburq, Pennsylvania ' 

Provided administrative direction and coordinated research projects for a 
public interest group based in Harrisburg, Pennsylvania, centered around 
issues related to the Three Mile Island Nuclear Power Plant. Prepared 
fundraising proposals, tracked progress of U.S. Nuclear Regulatory Com- 
mission, U.S. Department of Energy, and General Public Utilities activi- 
ties concerning cleanup of Three Mile Island Unit 2 and preparation for 
restart of Three Mile Island Unit 1, and monitored developments related 
to emergency planning, the financial health of General Public Utilities, 
and NRG rulemaking actions related to Three Mile Island. 

July 1978 - January 1980 

Chief Biological Process Operator - Wastewater Treatment Plant, Perry 
Township Municipal Authority, Hershey, Pennsylvania 

Chief Biological Process Operator at a 2.5 million gallon per day ter- 
tiary, activated sludge, wastewater treatment plant. Responsible for bi- 
ological process monitoring and control, including analysis of physical, 
chemical, and biological test results, procees fluid and mass flow man- 
agement, micro-biological analysis of activiated sludge, and maintenance 
of detailed process logs for input into state and federal reports on 
treatment process and effluent quality. Received certification from the 
Commonwealth of Pennsylvania as a wastewater treatment plant operator. 
Member of Water Pollution Control Association of Pennsylvania, Central 
Section, 1980. 

July 1977 - July 1978 

Wastewater Treatment Plant Operator - Borough of Lemoyne, Lemoyne, Penn- 
sylvania 

Wastewater treatment plant operator at 2.0 million gallon per day sec- 
ondary, activated sludge, wastewater treatment plant. Performed tasks as 
assigned by supervisors, including simple physical and chemical tests on 
wastewater streams, maintenance and operation of plant equipment, and 
maintenance of the collection system. 

September 1976 - June 1977 

Science Teacher - West Shore School District, Camp HHI. Pennsylvania 

Taught Earth and Space Science at ninth grade level. Developed and im- 
plemented new course materials on plate tectonics, environmental geology, 
and space science. Served as Assistant Coach of the district gymnastics 
team. 



-2- 



376 



September 1975 - June 1975 

Science Teacher - Carlisle Area School District. Carlisle. Pennsylvania 

Taught Earth and Space Science and Environmental Science at ninth grade 
level. Developed and implemented new course materials on plate tecton- 
ics, environmental geology, noise pollution, water pollution, and energy. 
Served as Advisor to the Science Projects Club. 

EDUCATION : 

B.S., Education, majors in Earth and Space Science and General Science, 
minor in Environmental Education, Shippensburg State College, Shippens- 
burg, Pennsylvania, 1975. 

Graduate coursework in Land Use Planning, Shippensburg State College, 
Shippensburg, Pennsylvania, 1977-1978. 

PUBLICATIONS : 

1. "Determining Mercalli Intensities from Newspaper Reports," Journal of 
Geological Education . Vol. 25, 1977. 

2. A Critique of: An Independent Assessment of Evacuation Times for Three 
Mile Island Nuclear Power Plant , Three Mile Island Public Interest 
Resource Center, Harrisburg, Pennsylvania, January 1981. 

3. A Brief Review and Critique of the Rockland County Radiological Emergency 
Preparedness Plan , Union of Concerned Scientists, prepared for Rockland 
County Emergency Planning Personnel and the Chairman of the County Legis- 
lature, Washington, D.C., August 17, 1981. 

4. The Necessity for a Prompt Public Alerting Capability i" the Plume Expo- 
sure Pathway EPZ at Nuclear Power Plant Sites , Union of Concerned Scien- 
tists, Critical Mass Energy Project, Nuclear Information and Resource 
Service, Environmental Action, and New York Public Interest Research 
Group, Washington, D.C.. August 27, 1981. * 

5. "Union of Concerned Scientists, Inc., Coiiinents on Notice of Proposed 
Rulemaking, Amendment to 10 CFR 50, Appendix E, Section IV. D. 3," Union of 
Concerned Scientists. Washington. D.C.. October 21, 1981. * 

6. "The Evolution of Emergency Planning Rules," in The Indian Point Book: A 
Briefing on the Safety Inyestiqation of the Indian Point Nuclear Power 
Plants , Anne Witte, editor. Union of Concerned Scientists (Washington. 
D.C.) and New York Public Interest Research Group (New York. NY), 1982. 

7. "Union of Concerned Scientists Comments. Proposed Rule. 10 CFR Part 50, 
Emergency Planning and Preparedness: Exercises, Clarification of Regula- 
tions. 46 F.R. 61134." Union of Concerned Scientists, Washington, D.C. 
January 15. 1982. * 



377 



8. Testimony of Robert D. Pollard and Steven C. Sholly before the Sub- 
committee on Energy and the Environment, Committee on Interior and 
Insular Affairs, U.S. House of Representatives, Middletown, Pennsylvania, 
March 29, 1982, available from the Union of Concerned Scientists. 

9. "Union of Concerned Scientists Detailed Comments on Petition for Rulemak- 
ing by Citizen's Task Force, Emergency Planning, 10 CFR Parts 50 and 70, 
Docket No. PRM-50-31, 47 F.R. 12639," Union of Concerned Scientists, 
Washington, D.C., May 24, 1982. 

10. Supplements to the Testimony of Ellyn R. Weiss, Esq., General Counsel, 
Union of Concerned Scientists, before the Subcommittee on Energy 
Conservation and Power, Committee on Energy and Commerce, U.S. House of 
Representatives, Union of Concerned Scientists, Washington, D.C., August 
16, 1982. 

11. Testimony of Steven C. Sholly, Union of Concerned Scientists, Washington, 
D.C., on behalf of the New York Public Interest Research Group, Inc., be- 
fore the Special Committee on Nuclear Power Safety of the Assembly of the 
State of New York, hearings on Legislative Oversight of the Emergency Ra- 
diologic Preparedness Act, Chapter 708, Laws of 1981, September 2, 1982. 

12. "Comments on 'Draft Supplement to Final Environmental Statement Related 
to Construction and Operation of Clinch River Breeder Reactor Plant'," 
Docket No. 50-537, Union of Concerned Scientists, Washington, D.C., 
September 13, 1982. * 

13. "Union of Concerned Scientists Comments on 'Report to the County Commis- 
sioners', by the Advisory Committee on Radiological Emergency Plan for 
Columbia County, Pennsylvania," Union of Concerned Scientists, Washing- 
ton, D.C., September 15, 1982. 

14. "Radiological Emergency Planning for Nuclear Reactor Accidents," pre- 
sented to Kernenergie Ontmanteld Congress, Rotterdam, The Netherlands, 
Union of Concerned Scientists, Washington, D.C, October 8, 1982. 

15. "Nuclear Reactor Accident Consequences: Implications for Radiological 
Emergency Planning," presented to the Citizen's Advisory Committee to Re- 
view Rockland County's Own Nuclear Evacuation and Preparedness Plan and 
General Disaster Preparedness Plan, Union of Concerned Scientists, Wash- 
ington, D.C, November 19, 1982. 

16. Testimony of Steven C. Sholly before the Subconriittee on Oversight and 
Investigations, Committee on Interior and Insular Affairs, U.S. House of 
Representatives, Washington, D.C, Union of Concerned Scientists, Decem- 
ber 13. 1982. 

17. Testimony of Gordon R, Thompson and Steven C Sholly on Commission Ques- 
tion Two, Contentions 2.1(a) and 2.1(d), Union of Concernei Scientists 
and New York Public Interest Research Group, before the U.S. Nuclear Reg- 
ulatory Commission Atomic Safety and Licensing Board, In the Matter of 
Consolidated Edison Company of New York (Indian Point Unit 2) and the 
Power Authority of the State of New York (Indian Point Unit 3), Docket 
Nos. 50-247-SP and 50-286-SP, Decenter 28, 1982. * 



378 



18. Testimony of Steven C. Sholly on the Consequences of Accidents at Indian 
Point (Commission Question One and Board Question 1.1, Union of Concerned 
Scientists and New York Public Interest Research Group, before the U.S. 
Nuclear Regulatory Conmission Atomic Safety and Licensing Board, in the 
Matter of Consolidated Edison Company of New York (Indian Point Unit 2) 
and the Power Authority of the State of New York (Indian Point Unit 3), 
Docket Nos. 50-247-SP and 50-286-SP, February 7, 1983, as corrected 
February 16, 1983. 



* 



19. Testimony of Steven C. Sholly on Commission Question Five, Union of Con- 
cerned Scientists and New York Public Interest Research Group, before the 
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in 
the Matter of Consolidated Edison Company of New York (Indian Point Unit 
2) and the Power Authority of the State of New York (Indian Point Unit 
3), Docket Nos. 50-247-SP and 50-286-SP, March 22, 1983. * 

20. "Nuclear Reactor Accidents and Accident Consequences: Planning for the 
Worst," Union of Concerned Scientists, Washington, D.C., presented at 
Critical Mass '83, March 26, 1983. 

21. Testimony of Steven C. Sholly on Emergency Planning and Preparedness at 
Commercial Nuclear Power Plants, Union of Concerned Scientists, Washing- 
ton, D.C., before the Subcommittee on Nuclear Regulation, Committee on 
Environment and Public Works, U.S. Senate, April 15, 1983, (with "Union 
of Concerned Scientists' Response to Questions for the Record from Sena- 
tor Alan K. Simpson," Steven C. Sholly and Michael E. Faden). 

22. "PRA: What Can it Really Tell Us About Public Risk from Nuclear Ac- 
cidents?," Union of Concerned Scientists, Washington, D.C., presentation 
to the 14th Annual Meeting, Seacoast Anti-Pollution League, May 4, 1983. 

23. "Probabilistic Risk Assessment: The Impact of Uncertainties on Radi- 
ological Emergency Planning and Preparedness Considerations," Union of 
Concerned Scientists, Washington, D.C., June 28, 1983. 

24. "Response to GAO Questions on NRC's Use of PRA," Union of Concerned Sci- 
entists, Washington, D.C., October 6, 1983, attachment to letter dated 
October 6, 1983, from Steven C. Sholly to John E. Bagnulo (GAO, Washing- 
ton, D.C.). 

25. The Impact of "External Events" on Radiological Emergency Response Plan- 
nTrTq Considerations , Union of Concerned Scientists, Washington, D.C., De- 
cember 22, 1983, attachment to letter dated December 22, 1983, from 
Steven C. Sholly to NRC Comnissioner James K. Asselstine. 

26. Sizewell 'B' Public Inquiry, Proof of Evidence on: Safety and Waste Man- 
agement Implications of the Slzewell PWR . Gordon Thompson, with 
supporting evidence by Steven Sholly, on behalf of the Town and Country 
Planning Association, February 1984, Including Annex G, "A review of 
Probabilistic Risk Analysis and Its Application to the Slzewell PWR," 
Steven Sholly and Gordon Thompson, (August 11, 1983), and Annex 0, 
"Emergency Planning In the UK and the US: A Comparison," Steven Sholly 
and Gordon Thompson (October 24, 1983). 



-5- 



379 



11. Testimony of Steven C. Sholly on Emergency Planning Contention Numoer 
Eleven, Union of Concerned Scientists, Washington, O.C, on behalf of the 
Palmetto Alliance and the Carolina Environmental Study Group, before the 
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in 
the Matter of Duke Power Company, et. al. (Catawba Nuclear Station, Units 
1 and 2), Docket Nos. 50-413 and 50-414, April 16, 1984. * 

28. "Risk Indicators Relevant to Assessing Nuclear Accident Liability Premi- 
ums," in Preliminary Report to the Independent Advisory Committee to the 
NAIC Nuclear Risk Task Force , December 11, 1984, Steven C. Sholly, Union 
of Concerned Scientists, Washington, O.C. 

29. "Union of Concerned Scientists' and Nuclear Information and Resource Ser- 
vice's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings 
the Consideration of Earthquake Effects on Emergency Planning," Union of 
Concerned Scientists and Nuclear Information and Resource Service, Wash- 
ington, O.C, Diane Curran and EUyn R. Weiss (with input from Steven C. 
Sholly). February 28, 1985. * 

30. "Severe Accident Source Terms: A Presentation to the Commissioners on the 
Status of a Review of the NRC's Source Term Reassessment Study by the 
Union of Concerned Scientists," Union of Concerned Scientists, Washing- 
ton, O.C. . April 3, 1985. * 

31. "Severe Accident Source Terms for Light Water Nuclear Power Plants: A 
Presentation to the Illinois Department of Nuclear Safety on the Status 
of a Review of the NRC's Source Term Reassessment Study (STRS) by the 
Union of Concerned Scientists," Union of Concerned Scientists, 
Washington, D.C., May 13, 1985. 

32. The Source Term Debate: A Review of the Current Basis for Predicting Se- 
vere Accident Source Terms with Special Emphasis on the NRC Source Term 
Reassessment Program (NUREG-0956) , Union of Concerned Scientists. Cam- 
bridge, Massachusetts, Steven CT Sholly and Gordon Thompson, January 
1986. 

33. Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, 
and Steven C. Sholly on behalf of State of Connecticut Department of Pub- 
lic Utility Control, Prosecutorial Division and Division of Consumer 
Counsel, regarding the prudence of expenditures on Millstone Unit III, 
February 18, 1986. 

34. Implications of the Chernobyl-4 Accident for Nuclear Emergency Planning 
for the State of New York, prepared for the State of New York Consumer 
Protection Board, by MHB Technical Associates, June 1986. 

35. Review of Vermont Yankee Containment Safety Study and Analysis of 
Co ntainment Venting Issues for the Vermont Yankee Nuclear Power Plant , 
prepared for New England Coalition on Nuclear Pollution, Inc., December 
16, 1986. 



-6- 



380 



36. Affidavit of Steven C. Sholly before the Atomic Safety 
and Licensing Board, m the matter of Public Service 
Company of New Hampshire, et al., regarding SeabrooK 
Station Units 1 and 2 Off-site Emergency Planning 
Issues, Docket Nos . 50-443-OL & 50-444-OL, January 23, 
1987. 

37. Direct Testimony of Richard B. Hubbard and Steven C. 
Sholly on behalf of California Public Utilities 
Commission, regarding Diablo Canyon Rate Case, PG&E's 
Failure to Establish Its Committed Design QA Program, 
Application Nos. 84-06-014 and 85-08-025, Exhibit No. 
10",935, March, 1987. 

38. Testimony of Gregory C. Minor, Steven C. Sholly et. al. 
on behalf of Suffolk County, regarding LILCO's Reception 
Centers (Planning Basis) , before the Atomic Safety and 
Licensing Board, in the matter of Long Island Lighting 
Company, Shoreham Nuclear Power Station Unit 1, Docket 
No. 50-322-OL-3, April 13, 1987. 

39. Rebuttal Testimony of Gregory C. Minor and Steven C. 
Sholly on behalf of Suffolk County regarding LILCO's 
Reception Centers (Addressing Testimony of Lewis G. 
Hulman) , Docket No. 50-322-OL-3, May 27, 1987. 

40. Review of Selected Aspects of NUREG-1150, "Reactor Risk 
Reference Document," prepared for the Illinois 
Department of Nuclear Safety by MHB Technical 
Associates, September 1987. 



* Available from the U.S. 
Public Document Room, 
Washington, D.C. 



Nuclear Regulatory Commission, 
Lobby, 1717 H Street, N.W., 



381 



® 



NEW ENGLAND NUCLEAR NEWS 
NUCLEAR OENERATIOM AS A PERCENT OF TOTAL ENERGY REQUIREMENTS 

APRIL, 1M7 

CAPACITY FACTORS 



Connecticut YankM 

Millston* 1 

MHIston* 2 

Millstone 3 

Vermont Yankee 

Maine Yankee 

Yankee 

Pilflnm 

'coastdown 

WeighlBd Ayngt Capacity Factor 



Nat 


Barrala 




Year to 




KilowatttMHira 


Oil Saved 


Menth 


Date 


Cumuletlve 






% 


% 


% 


334.216,000 


554,300 


80.0 


92.0 


76 


463,479,000 


766.600 


977 


970 


684 


597,711,000 


991,200 


94.9 


81 1 


625 


463,732.000 


752,500 


547 


687 


789 


353,972.000 


587,000 


95.8 


991 


687 


-0- 


-0- 


-0- 


641 


689 


97,011,000 


160.900 


•771 


865 


70.9 


-0- 


-0- 


-0- 


•0- 


529 



58.6% 



71 1% 



67.0% 



Total Nuclear Generation 
Total Energy Requirements 
Nuclear as % ot Total 
Total Barrets Oil Saved 



2,300.121.000 

8.184.000,000 

281% 

3,814,500 



TWELVE MONTHS ENDED APRIL 1987: 
Nuclear Generation: 

Nuclear as a Percent ol Total Energy Requirements: 
Barrels of Oil Saved: . 



32.699.000.000 kwhs 
32 percent 
54.227.000 barrels 




/-■■ 



New 
England 
Nuclear 
News 



ELECTRIC COUNCIL OF NEW ENGLAND 

54 MIDDLESEX TURNPIKE. BEDFORD. MA 01730 



382 




.e«-. 
' • -; . s 

JUNE 1987 
(April Data) 

CONNECTICUT YANKEE 

On April 16, the plant shutdown because of problems with turbine control valve #4. After 
chemistry holds and a load runback, the plant reached full power (94%) on April 2lst. 
The Institute for Nuclear Power Operations (INPO) will conduct its annual critique of plant 
operations beginning on June 8th. 

MAINE YANKEE 

Maine Yankee shutdown for refueling is proceeding generally according to schedule with 
startup expected in early June. Very small cracks found in the disks of both low pressure 
turbine rotors have necessitated the replacement of one and the repair of the other. 

YANKEE 

Yankee began its 18th refueling on May 2nd. The last cycle of the plant produced more 
than 2 million megawatthours over a 17 month period with a capacity factor of 93 percent. 

PILGRIM 

Pilgrim remained off-line during the month. 

VERMONT YANKEE 

On April 4, Vermont Yankee came down in power and took the turbine off-line to repair 
a small steam leak in a main steam drain line. The plant came back on-line the same day 
and operated at full power for the remainder of the month. 

MILLSTONE 1 & 2 

Millstone Unit 1 operated routinely for the month of April. A scheduled refueling outage 
will begin in mid-June and last for approximately 10 weeks. Millstone Unit 2 operated routine- 
ly except for a trip on April 16 due to a generator exciter field circuit breaker opening on 
presumed bistable transformer fault lndk:ation. Instruments in place to monitor the suspect 
bistable. The unit returned to service after a 20 hour outage on April ia 

MILLSTONE 3 

Millstone Unit 3 returned to service after a scheduled outage. After startup on April 11, 
the unit tripped on the next day while at 10 percent power level due to steam generator 
low level when turbine driven feed pump oscillated. Feedwater regulating control valve 
failed to open on demand due to a control air leak. The unit returned to service on April 
14 after being out for 29 hours. 



Qcne 



PuOiith»d Dy irt« 

Nuci««r inionnatlon Commtn** 

of mt Etsar'C Council 
ot New England 



383 






^ ,. NUCLEAR REGULATORY COMMISSION 

Z REGION I 

I til rsMK AVCfaus 

• KINO or roussi*. rCNNSVLVANIA I MO* 



AUG 27 1986 

Docket No. 50-293 

Boston Edison Company M/C Nuclear 
ATTN: Mr. James M. Lydon 

Chief Operating Officer ^ 
800 Boylston Street 
Boston, Massachusetts 02199 

Gentlemen : 

Subject: Confirmatory Action Letter 86-10 

This letter is to provide further guidance on the requirements we expect to be met 
prior to the restart of the Pilgrim plant. We acknowledge receipt of Boston 
Edison Company's (BECO) letter of June 16, 1986, in response to CtSTfi rmatory Action 
Letter (CAL) 86-10. Your actions with regard to the issues in CAL 86-10 appear to 
be thorough and technically sound., .My staff has a few remaining questions, which 
have been discussed with your staff and which will be documented in Inspection 
Report 50-293/86-25. 

In addition to the specific plant hardware issues involved with CAL 86-10, several 
other issues have been identified that require resolution prior to restart of the 
Pilgrim plant. Specific technical issues of concern include: overdue survPil- 
l ances. malfunction of recirculation motor generator set field breakers, seismic 
Qualification of emerqency diesel generator differential relays, and completion of 
Appendix R modifications. Please be prepared to discuss %he%e issues at our nex t 
management meeting at the plant on September 9. 1986! V/e would also like, to near 
at this meeting the scope and status of all vour Droarams related to restart o f 
.Pilgrim. These include (a) the results of your six week action plan for improve- 
ments, (b) the role of BcCO safety review committees, including the Program For 
Fxrpllpnce Task Force, in assessing readiness for restart, and (c) the readiness o f 
the plant and corporate staff to support plant startup, te sting, and operations . 

In light of the number and scope of the outstanding issues. I am not prepared to 
approve restart of the Pilgrim facility u ntil vou nrnvide a writtpn rppnrt that 
documents BECO's formal assessment of the readiness for restart operation . This 
assessment should include your detailed check list for assuring that all out- 
standing items have been satisfactorily resolved and that plant systems have been 
restored and prepared for operation. A formal restart program and schedule should 
also be submitted for NRC review and approval. This program should include hold 
points at appropriate stages such as critical ity. completion of mode switch test- 
ing, and at specific milestones during ascension to full power. Authorization to 
proceed beyond each hold point will be contingent upon my approval and will be 
based on my staff's evaluation of the operational performance of the plant. We 
will have substantially augmented NRC Inspection coverage during this restart 
period. 

Please plan to submit your readiness assessment and restart program and schedule 
at least fortv-five days before your planned startup from the c urrent outage. My 
decision on restart will be based In part on our review of these documents. 



384 



Your cooperation is appreciated. 



Sincerely, 



'7A>»»«**-'S 




Thomas E. Murley 
Regional Administrator 

cc; 

L. Oxsen, Vice President. Nuclear Operations 

A. E. Pedersen, Station Manager 

Paul Levy, Chairman, Department of Public Utilities 

Edward R. MacCormack, Senior Regulatory Affairs and Program Engineer 

Chairman, Board of Selectmen 

Plymouth Civil Defense Director 

The Honorable E. J. Markey 

J. D. Keyes 

Senator Edward P. Kirby 

The Honorable Peter V. Forman 

Sharon Pollard 

Public Document Room (PDR) 

Uocal Public Document Room (LPOR) 

Nuclear Safety Information Center (NSIC) 

NRC Resident Inspector 

Commonwealth of Massachusetts (2) 



385 



t'^r^M i «£GIONl 

^-' .3' KING or 'auniA 'IMNSVLVANIA 1t4M 

•...♦ 

APR £ 1997 
Cornet No. 50-293 

Boston Edison Compiny M/C Nuclear 
ATTN: M-. Ralph Bird 

Senior Vice President - Nuclear 
&Z0 3oyl stor Street 
=c;-.cn. Kasjacr.. setts CZ193 

Ge-*. 'em«n: 

Subject Systematic Assessment of Licensee Performtnct ( SALP) Reoort 
No. SO-293/86-99 

"-6 R»;-or, I SAl? esarc las reviewed and evaluated the ptrfor««itc« of actfv- 
T.-es at tn? Silgr-m Nuclear Power Station for the period Novtmbtr 1, :9£5 
tr,rcJ9^ January 31, 1987. The results are presented 1r ih« enclostd re?:'rV 
A -i9f'<; tc o-.scjss *.hi$ assessment will &» scheduled -for 4 •utually ictep:- 
iz' i Ci.e T-e -reting .•:: ss leld en or near the site so that appr<:p--'i-e 
i«- -.' -croc'jte r-e-acerent arc piant c'ficlals ccn discvss w1 ih ^% t-e 
:-.-?-:t.-i a-d ■.rc-.-esses r.oted. It is ojr <r^tnl that this iraetlng fet ecsrSinec 
«■•.'■ -.'e per-oc-c -.cra9eT:ent meeting to review Icorcv enen progpia status' 

'-t SALP Boa'S -centified significant recur-lng progra n veakntsses *- i:-e 

•■--rt-onal areas. Irprovewents, such as ir, tr,e are* of ene'sency preparediess. 
-e-s i^sc n?:sc However, the SALP Boarc *ound the rare of such charte '.aJ 

slow iurirg nost -' the assessment pencd. 

We recognize tfat the Boston Edison Company (BECo) has B;adt significant scaf'- 
•-; a-c '■'-ir^i.rt conritinents to inprcve per'ormance at t^:e Pllgrln rtaticr and 
»e se'iieve they a'e beginning to have a positive iaipact. Aj you art aware, t.-e 
S^C ■'. ><o»ing for progress In correcting the previously 1dtnt1f1«t lor:'te — 
:-ei'?-i at :ie P-lgrip Station prior tp c'ani -estart. particular'/ if-' --:■.: 
■'.'T-zi' areas -'tn a Category 3 rating. 

In ;-e;;-«t:or fpr the SAL? netting, please oc prtparttf t.9 discuss ysar tvalua- 
t-cn cr our asstssmtnt and tht status of ycur ptrfermancf ImprowtBtrt prc;-c-i 
Ary ton-rents you way have regarding our resort may be discuistd at f.t mssf-:. 
Acc-fi-all/^ you may provide written co.r-ents witnin 20 days after tht neet- 
'■''■<3 follotiMf our iiittting and rtctipt of your wrltttn rtsponst, tht tnclosea 
-eport, your rtsponst. and a summary of our findings ar d olanntd actio-* wi"' 
te ;"icea in tht NkC Public document Room. 



386 



63 



•ABLE 4 

•NFQRCEMEN- SUMMARY (11/:: '85 - 01/31/67) 

PILGRIM NUCLEAR POWER STATION 

Sj-se"- ane Sevfity Ltve' o' V'cltnons 



Seventy Level I 

Seventy Leve^ II 

Severity L%ve' HI 

Seventy Leve" IV 

Sevei-ity Leve' V 
2s. ■ ati on 



. • : ' o 1 1 n s 7s -u^ct'ca" Area 





1 
21 
6 
1 

IT 



•C^o 



>« ve''t. Le^e s 
'iT iV V .".'ev TcT«l 



'■' i". Ore'sv :-s 
■I'.-z' zz- zi' C:--.-:'s 
"i --.e-a-ce 
S.'.e- ■ 'ance 

E-c-ge-cy --e:i-?c-ess 
:'r.---.y Se-'ec.s<-cs 

Cj".agt M«n»ctfrer,t jno 
"ic-fiCiilo^ if.ivities 

L-censing Activities 

'c'*'ng anc C ja 1 i f icati on 
E" 'eC'.' veness 

-::.-c':fc :' :.r-y 



1 

3 

1 

5 3 





c 



ca'. S, :::--. 



a 



387 



6£ 



'ABA t iZo'-r.^-.^eC) 



Sumrn* ry 



.-spection 

JTese-". Severity Punctionil 

s^nsf '.eve' Arta V<o1it1on ^ 

£S-2i V Surveillance Instrumtnt chtnntl tt$t$ 

wert not bting performed 
monthly for tht r»tctor 
building vtnt and stack waste 
9<t Mnit.ors. 

= :-:* V Secj"t> P«nure to perform a 

Se'e;.e'--s oroper jtarcn of a package 

trcught 1 nto the protected 
area. 

if-:: ;• -'ir'. Post tri5 review 86-01 arc 

Zii'ii^c". 86-02 U: <.ec recalred 

recorde' .:*«i-t$. Inadeouat? 
cortrol - 3om let entries c 
O'sa&ied ur.r.w.'.c-.ators. 

i-:-:i ::: ne;-o1o;-Cc" * waste s+iioTe-t of solid 

If'.'-z'i metall'^c oiices on rrcn- 

lompactec trash lacked 
re;uirea jtrong packaglftg i-z 
Quality control seasures 

::-;£ :, Sj've-llirce Replaceme-nt squib charges 

were instaned '.n the star.:;, 
liquid ccTtrol syster frc- a 
3atch tCet hatf not be«n les.e: 
Curing a manual Initiation c - 
tne Standby Liquid Ccntrol 
System. 

c:-:: IV Ra::olcg'cal Radiatlor surveys of paciaceo 

Coitro's irradiated reactor components 

were not cocu'cnted on 
appropriate radiation survey 
forms anc macs. 

ci-'.l "., iji.-o-:e o' Quality c ontrcl reasu-es we -e 

!.= ■■-... -.at tc«e- -n trarsfe"-'re 

rac"c*ct" ■'• waste sh:pmerts 



388 



C3 



^ABlE i (Cont^njed) 



Sun.Tiiry 



inspecii on 

Report Severity Functional 

\.-:e' Level A^ea Violation 

S:-14 :v Assurance 0^ Prtvlously Idtntlfled 

Quall'.y intfliquaclis Involving 

survtillanct ttitlng of t-e 
high prtsiurt coolant 
Injtciion systtm were not 
corrtctea 'or six ncnths 

if-".-: V S j've- ' ' a'ce Failure to sroperly cont-cl 

•i«4$urinc and tejt equ'.c-art 

:5-Zl ;*' Su've-'^once Eatt«ry 'ater " saa C"sc'is-;e 

Test proceCjrs was not 
jpaatec t.o -e'"ect sj-stetr 
alteratlo-^s a-c rtstorat'sns 

:•:-;: '. . ^ssurir-e if Failure a nc '•'al f unct" on 

Cj«"':v fleoo't was nrt completei 

by engineer- -g ptrsoinei a'te* 
tney id«ntif-.ed deficient 
station *ire tar»lers. 

li-Z'- Su-ve'i"ance SurveiHa ice tests we^e 

performec wit*o^t inreperce--. 
veri f icat 'on of systei* res:.:-; 
ana system restoratic*.. 

iz-ll Oevation F--e '"-otecf:- Failure to conply ^it^ tre 

coiT.Ti traert to conduct 
quarterly fire brIgaCe ar-'': 
for all '1re brigade me-oe's. 

i:-j- IV Secur-ty Improper paci(.a9e se«r-cn ana 

Safeguards inadequate follow up. 

ii'li iv Pire Protection Fire brigade members riad -^t 

received the required 
training. 

i-.-2-. '. : t^'re '':-.e:fr- -'r» watc-.es 'ailed '.'-j ;e''':*" 

the required hourly ;atrc' o' 
the motor generator set -::- 



389 



66 



C . S uomi ry 

Inspection 

Serct 



Stve'i ty 
.evel 



"AqlE i (Contlnjtd) 



Tunctionil 

Arjj 



VioUtlon 



£6-37 
86-37 



IV 

IV 

IV 



Pire Protection 
^^odi ^ic«f.ons 

-■'e Prcterfcn 



In*dtquatt fire brigade Crii: 

Sif«ty-r«1»t«d BOdl'lCJiions 
were not perf or««d 1 n 
tccordtrcc with •pplicablc 
design rcqulriments. 

AdcQuate procedures and 
Cnwings hid not been 
estiblisned •^or the stiticn 
*ire wet sr s.ifStea. 



-■--i.i 



•-C1 



87-03 



'-33 



:v 



IV 



IV 



IV 



IV 



Oiogicc' 


Fi^.ure tc 1-; ement a 


rolS 


radioloQ ical co'trol orocec. 




for c'>ec«.inc ve-.icle'S 1ea>'- 




the site . 



-ve I ' laice 



's'. -tenance 



P'-e Protection 



Radiological 
Cc-t'o I s 



i'S'-'a'ce 



Fai.ure to ad^•re tc tie 
proceOwrtJ gnveming 
survei 1 ";.anc€ te;t1nc of t-e 
Post Acc'der-. Sampling 
Syster ( -^ASS ) system . 

Lack cf ;)rocedure guidance c- 
raaintena-ice cf th« neat 
tracing ciortrol drcjlt ri'j^i 
for the f'ASS system. 

Failure to take required 
action for Inoperable fire 
protecf.on eculpment. 

Failure to control a master 
key to a* 1 lc:k.ea nl;h 
'•adiation areas. 

Fai''u-e and "alfuncfon 
Sesc-t r. 3t cc-ipleteC afte- 
a sa'et. -'elated t-s trar,-?- 

cic rot r>ccur during a 
■survei ■'' ence test. 



390 



67 



'ABlE i (Continued) 



S jmiiupy 



inspection 

neoo't Severity Punctionil 

s.-:e- '.eve^ Area Violation 

i'-Qi IV Surveillince A survcHlanc* test on Staniiiy 

Gas Tre»UMnt Systtm failed tc 
meet tht Inttrt of the Tech 
Socc rcqulrttitnts. 

£7-Ci IV jurveillance Failure to calibrate measur'-g 

and test cqufsrent. 

t"-:- v' *!od" f ication Perforr>ing pcst-aodi f Icatlc" 

test or. the refuel bridge 
w^thou^ a;;-rved procedure 
changes. 

£"-;i 'A Surveillance Maste*- test r':;ram proceCL'ei 

00 not «cec. ---.ely acdress 
su'vei " I*'' : test ard pest 
modi f leaf test programs. 



391 



UNITED state: 
-" > / '■ ^- r..C;-=aF REGULATOR y COWV!S.S'0' 

i J ^ ■ --■ . RECn. : 



i ~--i 

MAY 2 1986 RECEl V C.L 



Docket No. 50-293 




Boston Edison Company M/C Nuclear 
ATTN: Mr. William 0. Harrington 

Senior Vice President, Nuclear 
800 Soylston Street i 

Boston, Massachusetts 02199 

Gentlemen: 

Subject: Systematic Assessment of Licensee Performance (SALP) 
Report No. 50-293/85-99 

This letter refers to the Systematic Assessment of Licensee Performance (SALP) 
of the Pilgrim Nuclear Power Station for the period of October 1, 1984 through 
October 31, 1985, Initially forwarded to you by our February 18, 1986 letter 
(Enclosure 1). This SALP evaluation was discussed with you and your staff at 
a meeting held in Plymouth, Massachusetts on March 5, 1986 (see Enclosure 2 for 
attendees). We have reviewed your March 26, 1986 written comments (Enclosure 3) 
and herewith transmit the final report (Enclosure 4). 

Overall, your performance in the operation of the facility was found acceptable 
although some areas were only minimally acceptable. 

As projected in our letter of February 18, 1986, a special In-depth team in- 
spection was conducted from February 18 to March 7, 1986 (Inspection Report 
No. 50-293/86-06) to determine the underlying reasons for the poor performance 
discussed above The team found that improvements were inhibited by (1) incom- 
plete staffing, in particular operators and key mid-level supervisory personnel, 
(2) a prevailing view In the organization that the improvements made to date 
have corrected the problems, (3) reluctance, by management, to acknowledge some 
oroblems identified by the NRC, and (4) dependence on third parties to identify 
problems rather than Implementing an effective program for self-identification 
of weaknesses. We believe these findings confirmed the SALP Board conclusions. 

We acknowledge your discussion of program and staffing improvements in plant 
operations, radiological controls and emergency preparedness. However, we 
believe that tht success of your programs depends upon resolution of the four 
principal factors Inhibiting Improvement noted above which, in turn, depends 
heavily on MingMwnt attitudes and aggressive followup. In this regard we 
request that you be prepared to discuss the scope, content and schedule of each 
improvement program at a management meeting scheduled for 1:00 p.m. on June 12. 
1986 at the NRC Region I Office. 



392 



TA5.; i. 
en-:':e--es' Su^^'<>ry (:c'i/84 - io/3i.-g;) 

PILSRIM NUCllAR power STAT ION 

FUNCTIONAL AREAS 

A. Pljnt Operjtions 

B. Rafiiologicil Controls 
C Kj-rterarce L ^::- •' ■ ca-.ioi-s 

D, Survei ■! "larce 

E. Efrergency Preparesress 
F Security I, Safeo-arcs 
G- Refueling & Outage ^'ar.agement 
H Licensing Acti vi ties 

":-.a"s 6> U.i'-:, .e.f' C : 2 17 5 2 27 





Seve 


-■ty 


Level 


_$ 






I 


II 


III 


IV 


y 


DEV 


Tota' 


- 


- 


- 


4 


2 




6 


- 


- 


1 


1 


1 




5 


- 


- 


- 


1 


- 




• 


- 


- 


- 


9 


2 




:z 


- 


-' 


- 


2 


- 




z 


- 


- 


1 


- 


- 




1 


- 


- 


- 


- 


- 







- 


- 


- 


- 


- 


- 






393 



Injp. 


Ipso. 


SevB'-ly 


Func-.iorjl 


No. 


D<tt 
n/1-11/85 


Lev»l 


krtt 


84-36 


IV 


P1«nt 








Op«rit1ons 






IV 


PUnt 
Optrjtions 



'AS.-: 5 

PILGRIM NUCLEAR POWER STATION 



V1o1«t1on 

F»11urt to conduct in adequate 
shift turnover for control room 
perjonnel auring refueling 

Failure to continuously momto'" 
source range mon-tl'S dj'-ng 
refuel 1ng 

84-39 11/21- IV Surveillance Failure to promptly Identify 

12/31/84 conditions adverse to quality 

(I.e. failure to initiate Fa'lu'e 
and Malfunction Reports) 

84-41 12/10-13/84 IV Emergency Failure to disemlnate emergency 

Preparedness planning information 

IV E-?':j-:y railurt to update the emerge'cy 
-'e:2-i:-iss r's' I'Z pr;:e3»-ei 

84-44 12/1S-1S/64 ::: Radiological Failure to follow radiation work 

Contro'S permit Instructions and failure 
to establish a procedure for a 
remote reading teledosimetry 
system 

65-Cl 1/1-31/E5 V Plant Failu'-e to maintain control room 

C;er4-.icrs staffing at levels required by 
10 CFR S0.S4 

IV Surveillance Failure to test the containTiert 
cooling subsysten Immtdlately 
when the low pressure coolant 
Injection system was inoperable 

65-03 Z/l'SS- IV S-'veil lance Failure to conduct surveillance 
3/4'£5 tests for the reactor protectim 

system (six txaaples) 

IV Surveillance Failure to conduct rod block 

surveillance Utts (five examples) 



394 



-3-i 



Inip. I'-s; Seve'ity Functional 

No. D«te Leve' A-ea V'ci*-.ion 

IV P1«nt Ftllurt to proilptly correct cc-" 

Operjtloni dltlonj *dver$» to gutlUy (i.e. 
fillurt to t*k.« timely «ctlon 
on Oujllty Aiiurtnce survt1ll»nce 
f indlngj) 

V Surveillance Fi11ur« to UM M» MSt current 

revision of ^ MiMtei^ ^tnce test 
procedure ^!- 

V Surveillance Failure to calibrate test eouip- 

■tnt within the calibrated penod 

85-06 3'5'E:- V Plant Failure to maintain an uncall- 

i/l/ll Operations brated local power range ironltor 

In a bypassed state 

IV Maintenance Failure to conduct a dioctyl 

phthalate test of HEPA filters 
following naintcnancc on the 
standby gas treatment system 

85-13 5/2C-24 '£5 V Radiological Failure to have the Operations 

Cc-t'ols Rev.e* Con-mittee (3RI) review 
tw: rai'c^:g-c4' procei-'es t-t 
failure to control worii in the 
fuel pool with a maintenance 
request 

Cevietion Radiological Failure to conduct an adequate 
Controls review of systems that could 
generate *n uncontrolled, un- 
monitored radioactive effluent 
release, as recominended in IE 
Bulletin 80-10 

85-17 6'13/85- IV Surveillance Failure to conduct a surveillance 
7/15/65 surveillance test of the 2S0 V 

battery system required by the 
technical specification and to 
follow station procedures for 
additional battery tests 

IV Radiological Failure to specify high radiation 
Controls area surveillance freoje-cies 
on radiation ••rd pennits 



395 



•-S-3 



Deviation Surveillince F«11ure to conduct inse'-vice 

ttjts as specified in an NRC 
Submittal 

85-20 7':6/S5- IV SyveiT lance FaMure to maintain the f-o 
8/19/85 level setting far the "B" and 

"C" Min sttaa Itne high radi- 
ation monitors within technical 
specification limits 

85-21 7'16/£5- IV Sur^eniance Failure to maintain secondary 
7/30/S5 containment 

IV Su'veil'ance Failure to test alternate safety 
system when an emergency diesel 
generator was found to be 
Inoperable 

IV Surveillance Failure to initiate Failure and 
Kalfunctlon Reports as required 
by station procedures 

85-24 8/6-e'e5 III Security Failure to maintain ar adeauate 

v'tii area barne- 

85-26 ; Z: £5- IV P'ant Failure to properly authorize 
9 2i/£5 Operations excessive licensed operator 

over-.ime as required by station 
procedures (thirty-five instances) 

£:-27 9 '16/85- Deviation Radiological Failure to install a protective 
5 ;' c: C;--.'c"s conduit 



396 




; UMTED STATES 

■- NUCLEAR REGULATORY COMMISSION 

I nCGION I 

/ U1 »*KK AVtH\Jt 

KIMC O' »«USSIA rtNNSVLVANIA IMM 

Ooc^.t NO. 50-293 j^^ ^5,3gc '^ ' ^- ^ ■ : ,. 

Boston Edison Company M/C Nucliar 

ATTN: Mr. William 0. Harrington 

Senior Vice President, Nuclear 
800 Boylston Street ''^'' C< 

Boston, Massachusetts 02199 

Gentlemen: 

SuBject; Systematic Assessment of Licensee Performance (SALP) Report No 50-293. 
84-34 and Your Reply Letter BECo 85-031 Dated FeOruary 12, 1985 

Thank you for your reply to SALP Report No. 50-293/84-34. In your lette' you s-e- 
sented additional information concerning assessments and requested we recofHioe- 
some of the assessments to Better account for the assessment period's extraora- narv 
circumstances (i.e., the extended outage for piping replacement). 

Based on our discussions with you at the January 23, 1985 management meeting and 
the information presented in your reply letter, the SALP Board founa it appropriate 
to revise the declining trend of the Category 2 rating for fire protection/house- 
keeping to a Category 2 rating with a consistent trend. We feel this is appropria*. 
as we may not have properly accounted for the extended outage m our evaluation 
for trend. However, we continue to feel that the extent of contamination tnat 
existed throughout the plant was inconsistent with a Category l rating. The en- 
closed SALP Report has been supplemented to reflect this change. The SAL? Boara 
also found that the other ratings should remain unchanged. 

With regard to the current status of your operations, we acknowledge the improving 
trend of your performance in the plant operations and maintenance areas ana en- 
courage you to continue your efforts in these areas. Further, we note me prog'ess 
Being made in implementing your recently established Radiological Improvement Pro- 
gram and encourage your efforts to decontaminate the plant, to reduce plant --aai- 
ation levels, to enhance oversight of the radiation protection program, and to 
establish support for the program by plant personnel. 

Your cooperation with us ii appreciated. 

Sincerely, 



Thoatas E. Hurley^ ^ 
Regional Adainistrator 



397 



38 



TABLE 2 
VIOLATION SUMWARY (7/1/83 - 9/30/84) 
PILGRIM NUCLEAR POWER STATION 



A. Number and SevtrHy Lev«1 of Violations 



Severity Level I 

Severity Level II 

Seventy Level III 

Severity Level IV 

Severity Level V 
Deviation 



ToUl 







1 
18 

6 
_1 

26" 



B. Violations Vs. Functional Area 



Functional Areas 



Severity Level 
I II III IV V OEV 



A. 


Plant Operations 




2 


5 


B. 


Radiological Controls* 


1 


7 


1 1 


C. 


Maintenance 




2 




0. 


Surveillance 




1 




E. 


Fire Protection and Housekeeping 








F. 


Emergency Preparedness 








G. 


Security and Safeguards 




6 




H. 


Refuel inq and Outage Management 








I. 


Licensing Activities 









Totals* 



18 



'Totals do not include three apparent violations and one apparent deviation in 
the area of radiological controls that were identified during inspection 84-25. 
NRC enforcement action was under review at the end of the assessment period. 



398 



39 



C. SumiTiary 

Insoection Insptction Stwerity 

Report No. Dat« Level 



83-19 



83-20 
83-21 



83-23 



83-24 



84-03 



84-04 



84-06 



8/15-10/3/83 



8/8-12/83 



8/22-24/83 



1/20-27/84 



2/7-3/12/84 



2/13-17/84 



IV 



i:/4-ll/7/83 IV 



IV 



11/8-12/31/83 IV 



III 



IV 



IV 



functional 
Area 



Violation 

Failure to review ana se- 
date special orcers 

Failure to vent 3iD-?5 '--- 
the hign point in i,-.e ::-» 
spray system 

Failure lo follow a Rao'- 
ation Work Permit 

Failure to schedule 'exte— 
nal audits 

Failure to document defi- 
ciencies in deficiency 
reports 

Failure to conduct an in- 
service test on a hign 

pressure coolant inject'in 
(HPCI) valve 

Failure to review a proce- 
dure for procuring safety- 
related items. 

Failure to record reactor 
vessel cool down rate 

Failure to label a contai-er 
of licensed material, use 
extremity dosimetry, anc 
instruct workers on radi- 
ation levels 

Failure to maintain a pro- 
cedure for the proper 
operation of the contain- 
Mnt atmospheric dilution 
system 

Failure tc follow a radi- 
ation work permit 



399 



40 



Inspection 
Beport No. 

84-11 



84-13 



Inspection 

Date 

4/23-27/84 



4/24-27/84 



84-14 



5/9-11/84 



84-22 



7/16-20/84 



Severity 

Level 

IV 



IV 



functional 
Area 



IV 



OEV 

IV 

IV 
IV 

IV 
IV 
IV 
IV 



B 
B 

G 
G 
G 
G 



Violat^'on 

Failure to maintain a :rc- 
cedure for control 'ing 
welding slag 

Failure to property -o.,-ew 
and approve cont- acto- :-t- 
cedures involv-ng trans^c- 
tation of radioacfve 
materials 

Failure to comply wifi fe 
requirements of a Cerf *•- 
cate of Compliance for a 
transport package 

Failure to properly docume"': 
a quality assurance program 
for transport packages 

Failure to fulfill a t-ans- 
portation training comm-t- 
mtnt 

Failure to instruct wor<e-s 
on the presence of raa:c- 
active materials 

Failure to survey '•adiation 
hazards 

Failure to implement pro- 
cedures consistent witn 
10 CFR 20 

Failure to control a 
security key card 

Failure to maintain pnoto 
ID badges 

Failure to respond to two 
vital area alarms 

Failure to maintain ore 
guard radio and one of'site 
communications net ooe'ao'e 



400 



41 



Insoection 
Report No. 


Inspection 
Date 


Severity 

Level 


Functional 
Area 


Violation 






IV 


G 


Failure to maintain e"i:- 
tive compensatory measu'-es. 






IV 


G 


Failure to maintain elec- 
tive compensatory measj-es. 


84-25 


8/6-10/84 


• 


a 


Failure to per'orm -ac-af: 
surveys 






* 


B 


Failure to instruct »«o-<e's 
on radiation hazaros 






». 


B 


Failure to properly approve 
procedures 






« 


B 


Failure to implement recom- 



mendations in Regulatory 
Guide 8.8 



84-26 



8/28-10/8/84 



Failure to properly approve 
QA program related proce- 
dures 



■Apparent violations and dtviations. Enforceffltnt action was under review at t.ie 
end of tnc asscssmnt period. 



401 



.<■•■' '"-^ 




NUCLEAR REGULATORY COMMISSION 
HtCION I 



w 



*a- sc 



KING O' VauSSi* PVNNftV(.vAf«l* i«40« 



i£? 1 i ?Sfi3 



.r J 



-:■:•.:■ Izi^' -;":3-> ** ! v.: ?a- 
i-'s «- *-''-a- Z -a'---:-.:'- 

5?- :' .:? -'es"Ce-t. N-r'ea- 
;■- :-^-. --^ S'. ""^^t 
E;3-.:- "ciSir-.ie-.-.:- ::irr 



RECEIVED 



-i"- ^'5' W. D. H. 

i.i.i:' ii'i"-".: issEi!*'Es" :- -::en5EE ^e^tcrmance (Si.= ) 

"-f s^I ^ec";' I Si-- Eca*: cc":,;tec a •■evie* on August 25. 15E2, a': s.a . 
:-T :9-':'-a"ce :' a:-.'v-,-es assoc^a-ec w^ti trie Oilg-im N^c'ea' -:«€' 5: = : 
*■? -9s-"ts :•' t"-s assess-e't a'e Ccc^me-tec in tne enc'csec i^^- 5:o'C -e: 
i -sef; "as res' sc-ec-'«c *3' Secte'-:e' 21. 19:;, at E'a-'t'se. "i :z 
ziz.ii :-■% asjsss^e'". 

-•- :"» ■'ii'.--^. yc. snc-'; De :'e:a'ec to 2'scjss our asses5ie"t a'z /C 
:'a-: ;: ■-:-:.« :e'-c"^a':e i"/ ri~"ents yCw may nave 'e;3'C-'c :.- '?::- 
*:.. :e :-s:.;se: at f» "leefc. Acc fona' ^y , you may cov'ce x-'tte" :: — 
'"■ — 11 Coj s a-'ter f^e Tsefng 

■: :-'■: :.- lesfc a-z 'ece':t o* you"- resoo'se. tie e^z'ziec '?:r't. ,:, 
'?;::';9. a't i s-mTa'> ;• c-' ••nr^rgs arc D^annec arfons ••■"'' :e z' iziz - 
-"5 ■'■'1 -.:"■; Icr.-e-t ncor. 



'at ■ : 



s ari's: • ats:. 



S'n;e'e' 



y . 




a'-ostecK.i 



an. j-'e:t3' 



Division o' Project anc 
Resiaent P'ograirs 



:3-'s As Statec 



A. V M;,..j,^ Ma-,age'. Nut'ea' Doe^ations Suooont 

- - *'at-lS. Stifcn "o-ags-- 



402 



3S 



'AS.i 4 






SunOS' a"; Seve'^'ty Ueve^ c* V'c'at'ofs 



Seve'-^y Leve" I 





Seve-^ty level II 





Seve-Uy Level III 


1 


Seve-ity Level IV 


9 


Seve-ity Level V 


20 


Dev-ations 


3 


Tota" Violations 


30 


Vc'at'3'^s Vs. "un;t'onal 


Area 



'otal Oeviat'ons 3 



Seve-'ty Leve's 



^jnc 


'::na. 


AREAS 




I 


II 


T » • 


:v 


V 


DEV 


. 


5 -a-. 


Ooe-a-. 


•ons 








4 


8 






Rac-o' 


loq-ical 


Cont-o''s 








1 


- 


' 


2 


Ma-'-.i 


!-ance 










1 
* 




• 


i 


Su've 


•" lance 
















5 


c.-e 1 


'-otect 


lon/Mousetieeoiic 










3 


'_ 


6 


E'^e'-aency P^i 


Boa-eflness 














■7 


5e:u'' 


'ty anC 


Safeguards 






1 


3 


2 




Q 


Re^ue' 


'-nc _ __ 
















C 


.•sensing Ac 


tivitle$ 















Totals 



1 



20 



Total Violations = 30 
Total Deviations * 3 



403 



'AS_£ i (Corf "uei) 



'SDe:for inspection Reoulre- 

-^ °iH SuB:e:t ments Seve- 



2-"-5 June It - BiOCH'ng ocen t f re T.S. V 

August I aoc- w-itnout proper 
control s 

Failure to evaluate T.S. v 

fire loading prior 

to moving combustibles 

into safety related 

area 

Failure to trinslate 10CFR50 V 
oesign bases into App. B 
drawings 

Failure to perform 10CFR50.59 V 
an aaequate safety 
evaluation prior to 
Changing a station 
valve lineup procedure 

Failure to maintain T.S. V 
a fire door position 
continuously annunciated 

Failure to perform Fire D 
daily cneciks of non- Protection 
alarmed fire doors Review 
as committed to tht 
NRC 

"' '^ August 2 - Failure to mane a T.S. IV 

prompt notification 

Failure to maiie a 10CFR50 V 
50.72 notification 

Failure to perform a T.S. IV 
Icaii rate test required 
by the LCO for an 
inoperable Vacuum Breaker 
Alarm System 



404 



'A=.E t (Zz' 



'jec 



Sjmmary 

I'lsoec^' on 



.psoecfon 

Date 
SeD'-emoe"- 7 
Oc-.ooer 18 



Sj: 



ra" ' jre tc 'ev se 
ccceaj'es 'or -ac^c- 
acf i/e C scna'-ges as 

comiT-ttec to tne NRC 



Recu-'e- 

me"*. s 

.• ce'-see 

Res:c' se 

V-c'a-.-on 
g-.-c-f 



Sev 9" 



32-29 



N/^C) 



0:-.obe' 19_- 
NovernDf 15 



January 31, 
1983 



January 25_ 
rearuary 28 



Imcooe' eouipment 
tagging 

Failure to p'-ooe-ly 
se*. a main steam 
safety valve 

Fai'ure to cooe'-ly 
confol CistnDution 
of tne Q-List 

Fai'iu'e to use proper 
methoas of access 
contro I 



1QC=R5: 
App, B 



Secy ty 
Plan 



Failure to prevent Security 
unautr.onzed entry into Plan 
vital area or followup 
on a security Oeficiency 

Safeguards information lCCFn.'3-4 
not properly controlled 
resulting in a loss of 
copy of tne site pnysical 
Security Plan 



Failure to pe-forw 
cnemistry samples 



,S. 



Failure to assure tnat lOCFRBO 
training certification App. B 
forms were completed 
prior to watcn assignment 



Failure to properly 
control nign pressure 
gas cylinoers 



T.S. 



:v 



ZC;- 



405 



42 



~AB.E 4 I Zor'.'r.ueC) 



No 



83-08 



Irsoection 
Cate 

March 22- 

Acnl 13 



May 9 ■ 
May 13 



Aor-l 4 
May 3 



(2) 



April 19 - 
May 23 



Sub:ec-. 



Reoui rfe- 

merts 



Seve- 



A-sa 



► a^ lure to imole- T . S . V 

ment a s'.atior oro- 

cecure for msoection 

ana clearing of me 

S3GT System inlet 

plenum 

Failure to conduct T.S. V 

an audit of the 

Radiolog'cal Envi'Dn- 

mental Monitoring 

P'ogram report when 

requi red 

Accepting, in receipt lOC^RSO V 
inspection, material App. B 
not in conformance 
with the P.O. Require- 
ments 

Failure to maintain 10CFR50 IV 
the 0-List App.B 

Failure to update the lOCrRSC. 71(e) V 
FSAR 

Failure to perform lEB 79-09 D 
preventive mainten- Commitment 
ance as committed 
to the NRC 

Safeauarcs information 10CFR73.21 IV 
not properly controlled 

Security access card Security IV 
key not properly con- Plan 
trol led 



406 



X^fj 



UNITED STATES 

NUCLEAR REGULATOSY COMMISSION 

REGION I 

631 PARK AVENUE 

KING O' 'Russia pemnsylvasia imm 

Ooci>.«t No. 50-293 

Boston Edison Company M/C Nuclear 
ATTN: Mr. William D. Haf'ngton 

Senior Vice Presiflent, Nuclear 
800 Boylston Street 
Boston, Massachusetts 02199 

Geni'emen: 

Subject; Systemafc Assessment of Licensee Performance (SA^O) 

This letter and its enclosures document NRC's assessment of t-e le'-'r'^a-ce :' 
licensed activities at the PUgrim Nuc>ar Power Station for tie oe'-ic Se:-.e-:e- 
1, 1981, to June 30, 1982. The enclosed SALP Report, dated A^qjst 12, 1951. 
Includes performance assessments for each of the nine functis-'al areas wn-:- 
were evaluated. These individual assessments were discussed witn you inc y:-- 
staff 6y Mr. R. W. Starostecki of this office on SepiemDer 1, 1982. at fe 
Boston Edison Company offices in Braintrae, MA. 

Our overall assessment of the performance of NRC licensed actwties at t"ie 
pilgrim facility Is that improvement has occurred since the organi rational and 
personnel changes which tooii place earlier this year. There 'ow appears to De 
a satisfactory level of management attention and involvement in plant sa'ety 
matters. This has ennanced the plant's performance with respect to ooeratlona' 
safety. We recognize tna^ efforts trt underway to improve tne management 
systems and utilization of resources at the Pilgrim 'aclHty. These changes 
and plans are documented in the Performance Improvement Plan which were sub- 
mitted to the NRC on July 30, 1982. However, we also rea'ize that 't wT' 5e 
several months before some of these improvements will be completed. Alt-^ougn 
performance has improved recently, some shortcomings have iee'^ noted and we 
have Included them in this report. In particular, we beHeve adS'fonal 
attention is warranted on your part in tne areas of day-to-aay o'ant opera- 
tions and fire protection/prevention activities. We wl'l be inc-easi-g ju' 
attention to these areas to ascertain if identified wea«.ne^ses ire ae-rg 
cor-ected. 

In the meeting of September 1. 1982, the NRC staff bene'-'ted ''om your co-nmerts 
concerning the SALP Program and the functional area performance assesS'Te-ts . 

I have also reviewed your letter of Septemeer 20, 1982 and have --c'jcec 
responses to your comments in this pacitage. The SALP Board also co^siae'ea 
your concerns and I had the benefit of their input. The results of these 
considerations are presented below. 



407 



TABLE 5 

VIOmTIONS (9/V81 - 6/30/82) 
PILGRIM NUCLEAR POWER STATION 
A. nxattr tnd Severity Level of Violations 

4. Interim IRC Policy Severity Level (September ^, T981 - Mareti 9. !982) 



Severity Level I 

Severity Level II 

Severity Level III 

Severity Level IV 

Severity Level V 

Severity Level VI 
Oeviitlon 





6 
5 

17 
2 
1 



*• H»C Policy Severity Levels (March 10. 1982 - June 30. 1982*) 



J«»»rity Level I 

5*'«nty Level II 

Sevtrity Level III 

Severity Level IV 

Sf erity Level V 
Oeviitlon 





1 
4 
3 
1 

38 



^'^1 Violations 
^'^^^^^^^gU L-Iunction.l Ar,. 
'^' ^^*^r 1.1981 -March 9. 1982 




Total Deviations 



Severity Levels 
II III IV 



VI 



3 



3 



l^_!!ll!ltenjne, 

4. Sury,ivw^ 

5. ^^^ iatectiQ, 

6. Egerq tt^y^^ -ji 

7. Securi 




9. Licenilna Aeti 4 





TT 



DEV 



408 

TABLE 5 (Continued) 
B. VloUtions Vs. Functlonil Art» 

(2) March 10, 1982 - Jun« 30, 1982* 



Severity Levels 



PJNriONAL AREAS 


I 


II 


HI 


IV 


V 


:ev 


1. Plant Ooeraffons 











1 


1 


1 


2. RadloloQical Controls* 











1 








3. Maintenance 











1 





3 


4. Surveillance 














2 





5. Fire Protection* 




















6. Emergency Preparedness 




















7. Security t Safeguards 








1 






















1 







B. Refuel 1nc 





9. Licensing Activities 











1 









Totals 



Total Violations ■ 38 
Total Deviations ■ 2 



• Dots not Include the following reports, not yet issued: 

82-19 • Resident Inspector 
82-20 - Special Health Physics 



36 



409 



TABLE 5 (Contlnuxj) 
C. Sumnary 

Inspection Inspection ... 

fif^ Date Subject Peo. Sev. -r«a 

a-1.19 June 15 - Failure to have an operable 10 CFS III 1 :9' 

Sept. 30 combustible gas control system SZ.a 

(multiple exuicles of design 
errors, procedural and drawing 
errors, and inadequate safety 
reviews] 

8',. 18 June 15 - Failure to Inform the NRC of T.S. Ill 1 (?: 

Sept. 30 tfie erroneous statement that an 

Installed system net the requlre- 
mnts of 10 CFR 50. U - Material 
False Statement 

81-19 August 18 - Failure to follow station pro- T.S. V 1 

Sept. 30 cedure 

81-19 August 18 - Failure to perform a safety 10 CFR IV 1 

Sept. 30 evaluation prior to disabling 50.59 

protection for an RhR pump 

81-21 August 31 - Failure to post a high radia- T.S. IV 2 

Oct. 2 t1on area 

81-21 August 31 - Failure to adhere to radiation T.S. V 2 

Oct. 2 protection procedures for 

radiation work permits. 

81-21 August 31 - Failure to post copies of NOV's 10 cn« V 2 

Oct. 2 Involving radiation protection 19 

81-22 Sept. 16 - RCIC containment Isolation valves T.S. HI 1 

S«Pt. 17 were left open when their control 

Instrumentation was Inoperable 

81-2* Dec. 1, 1981- Operation at drywell temperatures 10 CFR IV 1 

Jan. 18, 1982 (Povt FSAR descHptlon without 50.59 

adequate safety evaluations 

^^*^* 5!«' ii ^'*^- ^•^^"'^ " adequately prepare and T.S. V 1(4) 

"'•"• 18, 1982 Implement proceoures for coping 
with high drywell temperatures 



37 



410 



C. SuniMry 






Inspection 
No. 


Insotctlon 

Oati 


81-24 


Dec. 
Jan. 


1, 1981- 
18, 1982 


81-24 


Dec. 
Jan. 


1. 1981- 
18, 1982 


81-24 


Dec. 
Jan. 


1, 1981- 
18, 1982 


81-24 


Dm. 
Jan. 


1, 1981- 
18, 1982 


81-25 


Oct. 
Oct. 


15 - 
18. 1981 


81-26 


July 20, 1981 


81-35 


Nov. 
Nov. 


1 - 
30 


81-35 


Nov. 
Nov. 


1 - 
30 


81-35 


Nov, 
Nov. 


1 - 
30 


81-35 


Nov. 
Nov. 


1 - 
30 


81-36 


Nov. 

Dec. 


30, 1981- 
4, 1981 


81-36 


Nov. 

Dec. 


30. 1981- 
4, 1981 



TABLE 5 (Continued) 



Subject 



Pea. 



iev. 



Failure to ppomptly evaluate and 
correct conditions adverse to 
quality 



Security access card keys not pro- 
perly controlled 

Combustibles were not removed 
froB area near hot work 

Improper et^ulpment tagging 



Failure to have all ORG members 
present at a pr«-refuel1ng 
mtting 

Transported radioactive materials 
mIU) liquid 1n druns 

Control /Storage of combustible 
gas cylinders was not 1n accord- 
ance with station procedures 

Failure to establish and Imple- 
ment procedures for the control 
of combustible scrap, waste, debrts 

Failure to establish and Imple- 
ment procedures for the control 
of combustible o1l 

Control of foreign material 
during repairs to MSIV's was not 
In accordance with procedure 

A master surveillance schedule was 
not established 

T.S. Amendnents were not properly 
entered into controlled voliaies 



10 CFR 
50 App B 


V 




Security 
Plan 


» • » 


7 


T.S. 


V 


5 


T.S. 


V 


1 ( 


T.S. 


V 


8 


10 zn 

30.41 


ii: 


2 


T.S. 


V 


5 



T.S. V 

T.S. V 

T.S. V 

T.S. VI 

T.S. VI 



9 di 



38 



411 



TABLE 5 (Continue<i 



C, SuflB«ry 














Inspection 
No. 


Insptctl 
Date 


on 


Subject 


Pea. Sev. 


Ar» 


81-36 


Nov. 

Dec. 


30. 
4. 


1981- 
1981 


Program and procedures were not 
established for housekeeping and 
system cleaning that meet the 
standards stated in the QA Manual 


10 CR V 
50 Aoo 3 
QAM 


3 i: 


82-01 


Jan. 
Feb. 


18. 
28. 


1982- 
1982 


Workers were not properly In- 
structed of the storage and 
transfer of radioactive resins 


10 CFR V 
19.12 


2 


82-01 


Jan. 
Feb. 


18. 
28. 


1982- 
1982 


Procedures were not adequately 
established and lnvleninted to 
provide required numbers of SCBA 
units for fighting fires 


T.S. V 


5 


82-02 


Jan. 
Jan. 


1 - 
15. 


1982 


UncaHbrated bnjsh recorders 
Mere used during RPS surveillance 


10 CR V 
SO App B 


4 


32-02 


Jan. 
Jan. 


1 - 
15. 


1982 


Ma1nt«nanc« activities were per- 
fonwd without using approved 
procedures 


T.S. IV 


3 


82-02 


Jan. 
Jan. 


1 - 
15. 


1982 


Instrumentation was not calibrated 
at fr»quency specified In station 
procedures 


T.S. V 


4 


82-02 


Jan. 
Jan. 


1 - 
IS. 


1962 


Improper control of access to 
Vital Areas 


Security III 
Plan 


7 


82-04 


Jan. 
Jan. 


25 

29. 


*1982 


Failure to Isplenent procedures 
for Li^ and drawing change 
revisions 


T.S. V 


4 (1 


82-04 


Jan. 
Jan. 


25 

29. 


1982 


Drawings and procedures did not 
Identify the as-built condition 
of valves In piping systems 


10 CR IV 
50 App B 


1 


82-05 


Feb. 
Feb. 


1 - 
5. 


1982 


Untimely corrective action to 
Internal QA Audit Deficiency 
Reports 


10 CR V 
SO App B 


1 


82-06 


Feb. 
Feb. 


10 
12. 


1982 


Training and recual. program for 
personnel who operate and process 


ComnlttJiient DEV 
lEB 79-19 


2 



radioactive waste not Implemented 
as coonltted 



39 



412 



TABLE S (Cont1nue<i) 



C. Sunwary 




Inspection 
No. 


Inspection 
Date 


N/A 


Feb. 12. 1982 


82-10 


March 1 - 
April 4. 1982 


82-10 


March 1 - 
April 4. 1982 


82-11 


Feb. 25 - 
Feb. 28. 1982 


32-12 


April 5 - 
May 9. 1982 


82-13 


April 12 - 
April 16. 1982 


82-16 

i 


May 10 - 
June 13. 1982 



Subject 



Pea. 



sev. 



Ar.a 



Prompt Notification Systm 
(sirens) not Installed by 
February 1, 1982 

Performed maintenance on valve with 
red tag attached 

Plant shielding study md. 
(truck lock door panel) not 
completed as ststed 1n 
r«sponse to NRR 

An unauthorized adjustment was 

made to a leaking flange during 
the conduct of the PCILAT 

Failure to follow actions re- 
quired by T.S. with Inoperable 
reactor vessel water level 
Instrumntatlon 

Inadequate design control . for 
Interfaces and verification 

Failure to lock or control access 
to a high radiation area (stuck 
TIP drive) 



10 Cr^ 
50.54 



T.S. 



NURES 
0737 



10 CFR 
SO App J 



OEY 



IV 



T.S. IV 



10 CFR IV 
50 App B 

T.S. IV 



1 (3; 



9 (5; 

2 



( )* secondary area Involved 



40 



413 



Testimony Submitted by 

Stepfien J. Sweeney 

President and Chief Executive Officer 

Boston Edi son Company 

to the 

U.S. House of Representatives 

Subcommittee on Energy Conservation and Power 

of the 

Committee on Energy and Commerce 

July 16. 1986 



L^.-^<-^ *7^ 



.r 



414 



•N-qc cuc'::N 



Boston Ed' son Comoany appreciates tne opportunity to address a 
number of issues involving the Pilgrim Nuclear Power Station which are of 
concern to this committee, the Nuclear Regulatory Commission and to ne 
oersonaliy. At the outset let me stress that most of the issues raised o/ 
tne NRC in various reports and by this committee were of concef-n to -ne -ncre 
than a year ago and that corrective actions were underway as early as 
Septemoer 1985. As discussed in the following pages, those actions are 
meeti ng wi th success . 

In today's environment, public concern about nuclear power is 
heightened substantially. Public confidence in the technology and the 
institutions involved with it is at a low point. 

Boston Edison Company has a great deal of work to do in this 
environment to gain public confidence in our ability to manage and run 
Pilgrim Station. I personally will not be satisfied until we have acnieved 
a level of public and regulatory confidence tnat allows Pilgrim Station to 
place among the best, we have made an internal commitment to measure 
ourselves against the best, which is a significant change in now we are 
approaching our current problems. 

As will be evident in reviewing our testimony, we were historically 
plagued by not lool^ing outside to measure our success and to jndertaKe tie 
intensive self-criticism necessary to assess performance honestly and 
objectively. That has changed. We are moving in a new direction, one based 
on rising standards of excellence which are set, not by regulation, but Dy 
the performance of those plants judged to be among the best. 



415 



It s.'ioul:: 3e noted triat tf^e concer-s we are add'-ess-ng :;ca/ i'-e 

j,c<^3rent from tnose for whicn xe «*e'-e '.ned in 1982 T^g -ssjes t-ion ^e--? 

,fa'-'j-related and failure to compiy with rogulaticns. ^oday, f^e 'ss-es 
5 a ' " • / 

re not directly related either to compliance or to safety. They in-.tea: 
•nvo^'^e 3 rising stanaard of performance going far beycna -nere ::mc''a-:? 

; -1 rules to a mud proader dimension in tie regulatory process, '-a: -e^ 
I'mension is one that dictates comparisons and success is neasu^ed py 
relative performance. We endorse it. 

Before discussing our current activities, let me offer perspectwe: 

on three time i'rames. 

The first time frame is 1972 to 1979 and Three Mile Island, ^ur 
■7a-cr management shortcoming then was the ^ailure to recognize 'ully tnat 
:he operational and managerial demands placed on a nuclear power plant a'"? 
;e^y different from tnose of a conventional fossil-fired power plant. 
?c$tcn Edison strjctured its nuclear organization as part of a tradit'cna' 
:De^ating arm. ;^hile many members of the Pilgrim Station organization 
'eccgnized the differences in the technologies, they had limited success 'n 
jrgu'pg for the resources necessary to meet a set of standards that a'reaa.^ 
•ere "Sing fairly rapidly. This was also a period of poor quality fjel 
•h'ci resulted in significant internal radiological problems that affecte: 
t^e p' ant for years . 

Then came Three Mile Island. From March 1979 until early 1982 the 
same structure, under one vice president, attempted to deal with the 
:ost-TMi demands on operations and engineering, while at the same t'me 
3ursu'ng a construction permit for a second unit at Pilgrim Station. The 
sraf* increased dramatically to 200, 300 and then 400 people. It was an 
-nreascnaple wor<load for the structure and we paid a costly penalty 'zr -c: 
'8::gn;z;rg -^ .. 5550. qco in early 1932. 



416 



From 1982 unti ' 111(3-1985, we ooerared «1ti a new ana ■•"c^/ec 
■na-iageTien: structure mat recognized tne uniQue nature cf "uc'sar ccwe-- 
plants and the demands of the post-TMI period. »^e committed the ("inancal 
and human resources necessary to upgrade equipment and hardware ana to 
•nstali various improvement programs to meet NRC concerns. More than 
5300 million went into hardware improvements, the staff grew "rzm JCC to 
nearly 600 people and the organization was restructured under a san-or ;i:e 
president and two vice presidents. We achieved a significant Tieasur? o- 
success for wnich we were recognized by the NRC and in the plant's 
outstanding operating performance in both 1983 and 1985. 

But in managing the equipment improvements and the new TianageTient 
systems and programs we put in place, we didn't focus enough on wnat was 
going on outside the company in the industry and within the NRC. what x? 
didn't see because we were so internally focused was the fact that '.- = 
industry itself and the NRC were looKing under, behind and around al' of t-e 
narjware and management programs reaching for e<cellence. 

In our case, not seeing that put us in a defensive posture, .^e 
weren't identifying weaknesses that were inhibiting continued improvement 
ourselves. We weren't being self-critical, others had to tell us what -a; 
wrong. We weren't holding managers accountable enough for the end •'esu't of 
an action or inaction. We weren't wording well enough together. 

Those problems were very real, very serious and of great concern :o 
me and to the Board of Directors. I became particularly concerned about 
management performance, not management systems and programs, but the results 
of those systems and programs as measured by effectiveness In mid-i935. I 
asked the V'ce President of Nuclear Operations to investigate my concer-^s. 
which ne shared, and issue a report. As he progressed through the stu^y. "e 



417 



-,3 oce'- managers began iaentifying needs. In SecteiiDer 1985. «e '^z-n-i- 
.-e operator staff by a third, in Oecemoer, we reorganized oUnt "anage-?-: 
imorove reporting relationships and build in greater accountaoi ' i tv. 

In February 1986, the NRC issued their reoort. They said the sare 
►ning: We had attitude problems that were seriously interfering w-:n zw 
joil'ty to get the results we should be seeing given our fi-iancia' anc -..ra- 
'ssource commi tuents. 

By March, we had talcen a number of other actions, ail of wn;:n a-? 
jetailed in the following pages. We began eliminating those old att'tjces 
-lat «ere not serving us well and began to inject the nuclear organization 
,ith the sl^' 's and perspectives necessary to achieve a measure of 
cerfor-nance which would place us among the best. In the same time frame *e 
•nade further human resource commitments. We increased our emergency 
aijnning complement five-fold, we increased the number of radiological 
technicians 35 percent and we implemented an apprentice program for the 
'cng-term development of skilled personnel. 

The shutdown on April 12 gave us an opportunity to accelerate mar 
Cange. A different approach to problem solving was taken. It stressed a 
■nore deliberative and Integrated effort at identifying root causes and 
ran"; corrective action. In early May, a new plant manager and a new 
:ce'-it'ons section head were brought on board, nearly rounding out a new ■ ■: 
lemcer plant management team. Of the 16. II were new in their pos't'ons 'i 
fie :ast 8 months and 5 were new to the company. We nave new perspecf ves . 
''e have people with strong nuclear navy backgrounds, people with NRC 
'"scection experience and people who grew up professionally not in 
:cnventional fossil-fired power plants, but in nuclear plants. 



418 



- 3 - 



On May 27. having accsDted that management is jus: as imccrta-^: n 
-u'cment. ««e *cok, the unoracedented steo of giving the new plant manager 
d his new team additional time, while the unit was shut down, to become 
familiar -^^'^ '^® issues, to accelerate the development of new programs an:;, 
TOSt importantly, to infuse the organization with attitudes and dehavio' 
.riat will make those programs work,. These are attitudes tnat demand 
-elf-criticism, demand accountability, demand teamworK and demand results 
«hich go far beyond mere compliance with a set of rules, regulations ana 
technical specifications. 

Excellence is our goal. But excellence is, after all. an attitude 
..nich accepts nothing less. Achieving excellence will not be easy; we <ncw 
that. We <now our problems. We have made the human resource and financial 
commitment to solve them. We Know what has to be done and we are doing it. 
A; i result, I am confident we will, in time, demonstrate to you, to t"e 
Nuc'ear Regulatory Commission and the public that we have responded 
e^-'ectively to the concerns which are shared by all of us. 

As a final point. I know that an important question on tne minas :f 
many pecp"e is "why should Boston Edison be believed today given the 
problems over the years at Pilgrim Station''" 

I hope I already answered that question in part. It is perhaps t-e 
most difficult question and can only be answered fully by performance ove-- 
time. But in dosing I would underscore two major differences today from 
the past. The first is our forceful acceptance of the need *or us to 
measure our performance against an ever increasing set of standards set by 
those plants judged by industry and the NRC to be among the best. 



419 



•3 - 



'he second is the fact that we have alooted the iasic or;r:^o'=s 
criter'a for good -nanagement tha: are aopHed to the nuclear navy. --e_/ 
rg the same principles and criteria that are in evidence at all of the ::c 

rated plants. 

This is a demanding industry with a vital role in the soc'al and 
.,-oncmic health of the count-y. It operates in a demanding regulatory 
climate as evidenced by this hearing today. For us as a company -itn a 
single unit to succeed in this environment means that we must impos'e on 
ourselves the highest standards of performance found in the industry, ^e 

are doing just that. 

The balance of this filed testimony is arranged in the order of the 
si« sections on which you requested information in your letter of Ju-ly 2, 
1986. we have repeated your request at the beginning of each section. 



420 



SOSTt>\i £D'SCW 



Ralph G. Bird Ju / 3 . ' 53? 

3£Co L:r. 37-1 i i 

•^r. 3t3vsn i Varga. Z.'S-'.zr 
C'vs^c of Rsdcro'' ^'c'act:. I/II 
jniTsa ;:at33 Nlc'sj'- Regj'atory Ccmmin;cn 
-^asi'-;::", ^. Z. ;C:55 

License CPR-3S 
!:oc!<Let 50-293 

:nfc«ma-:cn segasoing 'iigsim station 

S.«--Ty ENHANCEMENT PqCGSAH 

Reference: NRC w3t:e'", ^'coosed EnhancsTient to tne Marfc I Containment - 
?'";r--Ti 3:a:xn, aated April 30. :987 

Gear Mr. Varga: 

As agraed iur'nq :^"7 i. '987 jiscussions between Franlc M'raglia. USNRC. 
ana Jcrn -j'tcn, 3os:cn i:'30n Comcany (3£Co). -e are suOmitt'ng :nis '■esccr^j 
to ycur 'ette*- t: 3E;c :at23 Aori 1 30, '937. Enclosed for jour ■ nfomat'cn •; 
a retailed :esc'":fcn or r-e Safety Ennancemenr ^r^gram (SE?) naraware 
tnanges tnat 5ECo las voiunrarily e'ected to ino'ement for Pilgrim Nuc'ea-- 
?ower Station (?NPS). "''^e ::escrioticn of procacural changes and oersonnei 
t'lining «ill ;e 'jr-i-snec .nder seoarate cover. A current 'nc! ementaricn 
jt'eaule -or t-e SE' iicdi f 'cat'cns -ill also 3e '"jmisned seoarate';/. A 
conait'cn is t-at tie Todi f icaticns scheduled during the current outage lo "c: 
'ecu'ra 3r";r governmental aooroval. Should this conaiticn not 2e "ne: 'o'" i".' 
of tiese /o'uitary too; • ' cifons . with the result tnat the cur-ent 
■ id' STientafon scnedule "nust oe extenaed. tnen 3ECo lill be unaole to 
■Tic'eTient fe af-ecteo .^cc'-" cations curing tne :jr-ent outage. 

iaa'ticnal dccumentat'on -till 5e avai'ao-e ':r 'sviaw ay fe NRC Sta^- i: 
3£Co's arainfw- of*i ces 0' tie PNPS site. CognTant 3E.Co oersonnei «i ' :e 
avaiiaole at those iccat-c-s "or i-scussion witn t-e Staff 

Cjr-ent eva'uafo-s of fe :e"e'it from tie SE' -nodi *icafcns are oasa: 
primar'ly ucon ei<t?'S"ve. a'tnaugn still ore 1 i binary , analyses and aua'itif-e 
engineering jjogments. "'-a' quantitative analyses -nust. in accordance 
witn the statea long te-^ goal of tne SEP. await final identification of 
■ncd'f 1 cat' ens i"c rcnoiet" tn of the Indiviaual "'ant Evaluation (!?£:•. 
3ECo undef-srancs fat '"e n=C intends to issue late-- this year a 
gener:: 'ette'- renu'-'ng ai' alants to serforn an !?£ as part of tne 



121 



ie '9' = 



'j.^yramen: '3 '53^63. Ei.- r'.r..j 

56-8'-:: 's'.: = ^. 






S3 :r93:'':ea :.- :-e 



9i3S "i9' '''"SS TC tCf^TiCt ~8 






:j -avo i"/ :^8;:-:-i< 






/i/^, 



3; ^: 



:c: Nuclear Reguiatary Conriss"on 
Docurent Ccntrol Des< 
Wasrnrigzcn, 2. C. 2255: 

Nuc'ear Requiatory CcmrnissiGn 

Region I 

531 ^ark Avenue 

King of Prussia, ?A 19406 

Senior 'IRC Resident Insoector 
^ilgrir:! Nuclear Power Station 

■^r. R. H. Wessman, Project ^-'anager 
^Division of Reactor Projects, I, 'II 
Qff-fce of Nuclear Reactor Regulation 
U.S. "Judear Regulatory Cctnmisslon 
7920 No»*or< Avenue 
Bethesda, ''10 2C8U 



422 



Vdchael S Dukaias 

Ciyvemor 

Charles V Barry 

Secretary 






'I 



.■J)'.^-f, ^fa.^.j^i£yui.l£/i± I' 2 / f S /i/T/ 7J7 -TTTS 



EXECUTIVE SUMMARY OF THE PROGRESS 

REPORT ON EMERGENCY PREPAREDNESS FOR AN 

ACCIDENT AT PILGRIM NUCLEAR POWER STATION 



EXECUTIVE SUMMARY 

Or. December 16, 1935, I t ransi^itted to the Gaverior a 
conprer.ens •- ve reoort on safety at Pilgrim Nuclear Power 
Statio". . T'-.is 13 a progress report about the activities cy 
state a-d local goverriT.ent, the Boston Edison Conpany, -he 
U.S. Nuclear Regulatory ConT.ission and the Federal Emerge-cy 
Management ^genrv since that time to address the concerns we 
found. 

In April of 19S6, operation of Pilgrim Station was 
halted because of several mechanical problems. The U.S. 
Nuclear Regulatory Commission has ordered that the Boston 
Edison Cor-pany keep the plant shut until a variety of 
corrections regarding the management and operation of Pilgri' 
Station have been made. As of this date. Pilgrim remains 
closed, although Boston Edison has asked the NRC for 
permission to restart the facility. 



Rad 
fac 
saf 
man 
the 
pla 
ser 
rec 
unl 
add 



In 
iolog 
ility 
e t y . 
ageme 
reac 
nning 
ious 
ommen 
ess a 
resse 



my 
ical 
wer 
I f 
nt o 
tor. 

- Pl 
and 
ded 
nd u 
d. 



ece 

Erne 
e no 
urth 
f th 
In 
ant 
the 
that 
ntil 



ber, 1986 report, I concluded that 

gency Response Plans for the Pilgrim 

t adequate to protect the public health 

er identified serious problems regardm 

e power plant and the engineering safet 

my view, these three issues -- emergen 

management, and reactor safety -- were 

weaknesses and deficiencies so severe t 

the plant should not be allowed to res 

these concerns had been satisfactorily 



y o: 
so 



There has been a considerable amount of activi! 
levels to address these concerns since "" ronnn- u?,> 

In 



at a; 

issue': 



423 



-2- 



MCDA/OE? has InstitJted a plar'.r.i.r.g p 
and local level and revisions are well un 
addition, a new system has been installed 
notification in the event of an accident 
We now have the advantage of a new N-iclea 
Preoaredness Program and a professional s 
first time is dedicated to off-site emerg 
and planning. This new program and staff 
the Governor's initiative in the Fiscal Y 
The Governor has requested additional fun 
program as a supplementary appropriation 
fiscal year. 



roce 

for 
at P 
r Sa 
taff 
ency 

are 
ear 
ds f 
for 



ss a 

wav . 

off 

ilgr 

f ety 

wh 1 

pre 

the 

1988 

or t 

the 



t the 

In 

-sits 

im St 

Ener 

c h f o : 

pared: 

r e s u : 

b u d g ; 

he ne- 

c u r r e r 



at ; 
aer 



the 

!33 



Nonetheless, I continue to make the finding that 
adequate plans for response to an accident at Pilgrim Station 
do not exist, and I reaffirm my earlier position that the 
Pilgrim facility should not be allowed to restart until s-^ch 
plans have been fully developed and have been demonstrated to 
be workable and effective through a graded exercise of all 
plans and facilities. 



This finding is based on the fac 
area in which I found a deficiency to 
1936 report substantial work remains 
determination of adequacy can be made 
of a new Evacuation Time Estimate and 
Study by state and local authorities 
ETE is one of the most critical piece 
entire process and the foundation of 
planning. Our preliminary review of 
more resources are required to succes 
traffic management plan. The shelter 
prepared by Boston Edison has been re 
"for further study because is was foun 
inadequate . 



t that in every critical 

exist in my December, 
to be done before a 

For example, analysis 
Traffic Management 
IS still underway. Tr.e 
3 of information in the 
effective emergency 
the ETE suggests that 
sfully implement the 

survey which was 
turned to the company 
d to be woefully 



Plans and implementing procedures for special need 
populations remain incomplete, and it may be necessary 
undertake an additional survey of people who would need 
assistance in emergency response or to do further stati 
analysis of this matter. The development of implementi 
procedures and the identification of resources to care 
school age populations also requires additional work, 
regard to the adequacy of reception centers, the questi 
need for a facility to serve people in the northern por 
of the EPZ remains open. We cannot make decisions on t 
need for or identification of a third reception center 
Boston Edison has provided us with an analysis of the 
adequacy of the existing two reception facilities. 



s 

to 

s 1 1 c a : 
ng 
for 
In 

on of 
t ion 
he 
u n t i 1 



424 



-3- 



With regard to plant management, we have seen numero-s 
changes in Boston Edison's personnel and organization for 
management of Pilgrim Station. The most notable change is 
the appointment of Mr. Ralph G. Bird as Senior Vice 
President, Naclear, who directly reports to the company's 
chief executive officer. Yet despite these changes, I car.-.o- 
say at this time that the management problems have been f-illy 
resolved. For example, we are concerned about recent 
incidents including violation of NRC regulations m the ar?a 
of plant security, and allegations of excessive overtime 
worked by utility employees. We are also concerned by Boszz- 
Edison's action to refuel Pilgrim Station without having 
responded to my objections and the objections of several 
state legislators. 

The Systematic Assessment of Licensee Performance ( 3A1? ) 
perfomed by the NRC is the most comprehensive study and 
reoort on nuclear management at Pilgrim Station. The last 
SALP report was issued on April 8, 1987 and it showed 
deterioration in several aspects of nuclear management since 
the last report. Until a similarly comprehensive analysis of 
management under the new organization has been conducted and 
the above concerns resolved, I cannot say that our management 
concerns have been addressed. 

With regard to reactor safety issues, we have carefully 
reviewed Boston Edison's "Safety Enhancement Program" (SEP). 
The SEP has been undertaken since the issuance of a "Draft 
Generic Letter" from Mr. Robert Bernero of the NRC concerning 
safety at Mark I containment structures such as the Pilgrim 
containment. We have two major concerns in the area of 
reactor safety. 

First, despite the fact that the NRC letter was prompted 
by a finding that there was a high probability of Hark I 
containment failure during certain severe accident scenarios, 
the NRC has yet to adopt an official position regarding 
safety enhancement. Moreover, according to NRC Region I 
Administrator William Russell, with whom my staff and other 
state officials met at NRC's regional offices .-. King of 
Prussia, Pennsylvania on October 8, 1987, enhancement of the 
Mark I containment at Pilgrim is not an issue that the NRC 
believes must be finally resolved before restart. 



Our second concern is the uncertainty that continues to 
exist about at least one feature of the Boston Edison SEP, 
the direct torus vent. No concensus has been reached on 
whether installation of the torus vent creates unreviewed 



425 



-4- 



safety issues or if the torus vent is authorized, how it w. 1 1 
be used in the event of a severe nuclear accident. 

The findings of my December, 1986 report have been 
strengthened by two other analyses of safety at Pilgrim 
Station. The Special Joint Legislative Commission to Study 
Pilgrim Station has issued its report which further studies 
and documents many of the same safety concerns. In addition, 
the Federal Emergency Management Agency has issued a 
Self-Initiated Review of plans for response to an accident at 
Pilgrim Station. Based on several of the issues raised m my 
report FE^A has changed its interim finding and now agrees 
that the off-site plans for an accident at Pilgrim are not 
adequate . 

FEMA has transmitted their new finding to the Nuclear 
Regulatory Commission. However, the NRC has yet to indicate 
whether or not development of adequate off-site plans will be 
a condition to the restart of Pilgrim, we are not satisfied 
with the view recently expressed by the NRC Region I staff 
that emergency planning problems must be "addressed" before 
restart. Such problems must be satisfactorily resolved 
before restart. Off-site response plans are just as 
important as nuclear management and reactor safety in 
protecting the public from an accidental release of radiation. 

Therefore, for these reasons — the absence of adequate 
emergency response plans, lack of demonstrable assurance that 
management problems have been solved, and uncertainty about 
the safety of the Mark I containment structure — I continue 
to find that Boston Edison has not met the heavy burden of 
showing readiness to restart the Pilgrim Nuclear Power 
Plant. I also continue to believe that it remains to be seen 
if adequate emergency response plans can be developed and if 
all other safety issues can be resolved to our satisfaction. 

Finally, I recommend that in light of the number of 
outstanding issues and their complexity, and Boston Edison's 
evident determination to press ahead with the effort to 
restart, that there should be a full scale public hearing by 
the NRC before any decision is made regarding the restart of 
Pilgrim Station. 



October 14, 1987 CHARLES V. BARRY 

SECRETARY OF PUBLIC SAFETY 



1051J 



426 




THE COMMONWEALTH OF MASSACHUSETTS 
EXECUTIVE DEPARTMENT 

CIVIC D6FENSE ACCNCT *n0 OFFICE OF EME«GENCY PREPAREDNESS 

400 WOBCESTEB ROAO 

PO BOX I48e 

FRAWINGKAM. MASS 017010317 




MICHAELS DUKAKIS 
GOVERNOR 



ROBERT J BOULAr 

DIRECTOR 



September 18, 1987 



Mr. RalDh Bird 
Senior Vice President 
Boston Edison Company 
800 Boylston Street 
Boston, Massachusetts 

Dear Mr. Bird: 

My staff has reviewed the August, 1987 "Study to Identify 
Potential Shelters in EPZ Coastal Region of the Pilorim Nuclear 
Power Station," which was prepared for you by Stone and Webster, 

We find that this study is deficient in several respects and 
that additional work is required to provide information to 
local officials which is sufficient to suoport development of 
implementable shelter utilization plans. I have attached a 
copy of a memorandum orepared by my staff which details our 
specific concerns regarding this study. 

If you have any questions or observations reoarding our 
evaluation, please contact Buzz Hausner of my staff. 

Thank you for your cooperation in this matter. 



Sine 




Director 



cc: Assistant Secretary, Peter W. Agens, Jr. 
Deputy Director, John L. Lovering 
Mr. Buzz Hausner 



427 




EXECUTIVE DEPARTMENT 

Civil OC'CnSE AOCnC* ^**0 0*'iCE 0' (MEWJtMCT PnCPAREDNCSS 

400 WOPCESTCn »»O*0 

PO BOX 1490 

FflAMINOMAM, UASS OirOlfliW 



'-. "c 



^*^ t^*- 



^■IfMO^^" 



MrCHAEL S DUKAKIS 

OOVEBNOfl 



ROBEflT J eoULAY 
OIOCC'OB 



TO: 

FROM: 
IN RE: 

DATE: 



DIRECTOR BOULAY 

BUZ^^USNER 

SHELTER SURVEY OF PILGRIM EPZ PREPARED BY BOSTON EOISOrj 
COMPANY 

SEPTEMBER 11, 19fl7 



We have made a preliminary review of the shelter survey of the 
Pilgrim EPZ which was prepared by the Boston Edison Comoany and 
its consultants. While this rtocunient comoiles some very useful 
data, we feel that more work must be done to estimate the 
effectiveness of shelter as a protective action. 

Our principal concern is that we must be able to put data in the 
hands of local officials which are sufficient for the development 
of shelter utilization plans for all areas of all five 
communities within the Pilgrim EPZ. With this in mind, we have 
the following comments. 

The survey only covers an area approximately one mile 
wide along the coast. The shelter capabilities of the 
entire EPZ must be surveyed and reported. 

The survey does not separate out those structures which 
could "most reasonably" be used as shelters from those 
where shelter is less appropriate. 

For Instance, it would help to have a separate list of 
public buildings and facilities for each town, 
including an estimation of the actual useable shelter 
space and protective factors for shelter under 
government authority. 

Many of the shelters listed, such as jewelry stores and 
pharmacies are clearly not suitable for public 
shelter. In a severe emergency, every available 
resource will of course be put to use. However, to 
develop an implementable shelter utilization plan, 
local officials must be able to match estimated needs 
with the most appropriate resources available. 



428 



Director Boulay 
Page 2 



Regarding protection of the heach oooulatlon, the 
survey identifies shelters within a mile of the coast 
but does not indicate the distances that beach goers 
would have to travel to find shelter. In addition, thp 
survey must demonstrate that adequate proximate shelter 
Is available for the total population at the individual 
beaches . 

For instance, Ouxbury beach is about seven miles lonq 
and the survey should indicate the distance peonle at 
Saqulsh Head are required to travel to reach adequate 
shelter. Further, an implementable shelter utilization 
plan must demonstrate that the nearest shelter would 
not be full to capacity before the people at the most 
remoten^oirits of the beaches arrived. 

The survey must identify adequate shelter which is 
handicapped accessible. 

The survey does not distinguish between available space 
and usable space. For instance, residents of Plymouth 
have indicated to us that some basements listed in the 
survey are no more than crawl spaces. Crawl spaces 
cannot be considered for public shelter. Further, in 
most buildings, a good deal of floor area will be 
occupied by machinery, counters, office furniture, et 
cetera. The survey must identify accurately the actual 
useable shelter space available in each structure. 

Stone and Webster uses a FEMA nuclear attack value of 
ten square feet per person to estimate the potential 
population which can be sheltered. Local Civil Defense 
Officials may wish to allocate more space — uo to 
twenty square feet per person — in their utilization 
plans. The value used in the survey overestimates the 
potential capacity of various buildings. We doubt that 
17,000 people can be sheltered at Ouxbury High School, 
or that 89,700 can be sheltered at the 5 Cordage Park 
Buildings. 

The survey must demonstrate that public shelters are 
free from asbestos and other environmental hazards. 

The report estimates residential "shelterinq 
capability" in individual communities as between 53% 
and 81X. These figures indicate that a significant 
number of residents do not have adequate domestic 
shelter and emphasize the need for a full study of 
public shelter capacities throughout the entire EPZ, 



429 



Director Boulay 
Page 3 



Further, even if It can be established that the vast 
majority of residences offer adeouate shelter, local 
officials must be preoared to offer public shelter of a 
known protective capability to residents who demand 
assistance . 

This report makes no definitive statement of what 
constitutes adequate shelter to protect oeoole from the 
effects of a radiolooical release from Pilorim 
Station. This is necessary to determine what 
facilities are most appropriate for a local shelter 
utilization plan and to determine the public shelter 
needs of each community. 

In summary, we would say that this survey is a useful beginning 
but that much more work is required before we can assess our 
ability to develop implementable shelter utilization plans 
consistent with the public safety concerns in Secretary Barry's 
report to the Governor. 



cc: Assistant Secretary Peter W. Agnes, Jr. 
Deputy Director John L. Lovering 



430 



BOSTON EDISON 

itecy \,e 0*''ces 

800 Scyisto'". ifee' 

Bailor, Vassacruse'.tsC2'99 



Ralph G. Bird September 1 7 . 1987 



U.S. Nuclear Regulatory Commission 
Document Control Desk 
Washington. D.C. 20555 

Docket 50-293 
License No. DPR-3.' ^ 

Subject: Boston Edison Company Request for 
Exemption from 10 CFR Part 50. 
Appendix E, Section IV. F. 

Dear Sir: 

In accordance with 10 CFR section 50.12(a). Boston Edison Company requests 
that the Nuclear Regulatory Commission (NRC) grant a one-time exemption from 
the requirements of 10 CFR Part 50. Appendix E. Section IV. F., that would 
authorize the next biennial full participation emergency preparedness exercise 
for the Pilgrim Nuclear Power Station (Pilgrim) to be conducted in the second 
quarter of 1988. The schedule for future biennial exercises will not be 
affected by this one-time exemption, but rather will continue to provide that 
such exercises will be conducted every second year ( i.e. . the following 
biennial exercise will be held in 1989). 

The proposed deferral of the full participation exercise has been discussed 
with the Commonwealth of Massachusetts (Commonwealth) and local emergency 
response officials. All of the parties have indicated that they support the 
proposal . 

The request will not affect the onsite exercise at Pilgrim planned for 
December 9. 1987. 

The requested exemption is necessary because the Commonwealth, the local 
governments within the ten-mile plume exposure pathway emergency planning zone 
(EPZ) and the two emergency reception center communities are at present 
engaged in implementing numerous improvements in their offsite emergency 
preparedness programs, with the assistance of Boston Edison. These 
improvements include revision of the emergency plans of the local governments 
revision of the Massachusetts Civil Defense Agency (MCDA) Area II plan as well 
as the Commonwealth's state-wide plan, the development of revised related 
procedures the development and implementation of training programs for 
officials and emergency personnel, and the upgrading of Emergency Operation 
Centers (EOC's). A substantial commitment of resources and time has been made 
to accomplish, these improvements, and the work is expected to continue through 
the remainder of the year and early 1988. 



431 



U.S. Nuclear Regulatory Commission 
Page 2 



In view of these extensive ongoing efforts, the Commonwealth and the local 
governments have indicated that they are not able to participate in an 
exercise during calendar year 1987. Moreover, it is apparent that under these 
circumstances, conduct of the full participation exercise will be much more 
effective after the ongoing improvements have been implemented. In granting 
one-time exemptions authorizing deferral of exercises for licensed plants in 
the past, the NRG has recognized that the most effective and beneficial 
exercises are those which include the full-scale participation of State and 
local governments and that it is appropriate to defer an exercise until 
program revisions or facility improvements have been completed. 

Since the last full participation biennial exercise at Pilgrim, Boston Edison 
has held an onsite exercise at Pilgrim 1n December 1986; has held 
quarterly onsite drills in March, Jjne and August of 1987; and has scheduled 
its annual onsite exercise for December 9, 1987 (in which the Commonwealth 
will exercise various offsite objectives as described in BECo Ltr. #87 -147 
"Scheduling of Pilgrim Onsite Exercise"). The previous exercise and drills 
have included limited participation by the Commonwealth, and the March and 
June 1987 drills included limited participation by several of the towns. The 
towns within the EPZ have also cooperated in the full scale siren test 
reviewed by FEMA, which was conducted on September 29, 1986. In addition to 
its activities involving Pilgrim, the Commonwealth has also participated in 
full participation exercises at the Yankee Nuclear Power Station in June 1986 
and is scheduled to participate In a full participation exercise at the 
Vermont Yankee Nuclear Generating Station during the week of November 29, 1987. 

This request meets a number of the special circumstances listed In Section 
50.12(a)(2) 

First, granting the request will provide only temporary relief from the 
applicable regulation and the licensee has made good faith efforts to comply 
with the regulation. Over the past year, Boston Edison has assisted 
Commonwealth and local authorities In a variety of ways to accomplish as many 
improvements as possible In their offsite emergency response programs. For 
example, Boston Edison has developed substantive Information for the 
enhancement of those programs. The major products of this effort Include the 
"Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update" 
(August 18. 1987) prepared by KLD Associates, Inc. and "A Study to Identify 
Potential Shelters In the EPZ Coastline Region of Pilgrim Nuclear Power 
Station" (August 1987) prepared by Stone & Webster Engineering Corporation, as 
well as Information generated In surveys to Identify the special needs and 
transportation dependent populations within the EPZ. 

In addition. Boston Edison Is providing assistance to the local governments in 
their offsite emergency program enhancement efforts in accordance with the 
Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15, Acts of 1950 
as amended). This assistance Includes the provision of two professional 
planners to work under the direction of the officials of each town within the 
EPZ In upgrading its plan, procedures and training; one 



432 



U. S. Nuclear Regulatory Commission 
Page 3 



professional planner to assist each reception center community; and four 
professional planners working under the direction of MCDA in the upgrading of 
the MCDA Area II and Commonwealth program. In the first half of 1987, Boston 
Edison provided introductory emergency training to about 350 personnel within 
the five towns in the EPZ and enhanced introductory training modules are 
currently being prepared for review by the MCDA prior to further 
implementation. The planners provided by Boston Edison have also begun to 
prepare task-based modules for training of specific categories of emergency 
personnel and will be available to participate in the training programs. In 
addition. Boston Edison is executing agreements with each of the five towns 
within the EPZ, as well as the two reception center communities, for 
assistance in the renovation of their EOC's. Moreover, four of the five EPZ 
towns and both reception center communities, to date, have accepted BECo's 
offer of funding support for full-time civil defense staff positions. 

Second, literal compliance with the regulation would not serve its 
underlying purpose and would result in undue hardship to Commonwealth and 
local emergency response agencies by requiring an exercise of portions of the 
offsite emergency plans that are in the process of significant revision and 
improvement. This would necessarily Involve disruption of the ongoing process 
of implementing these changes, and consequently, the imposition of additional 
costs and delay In accomplishing the planned Improvements. The NRC's 
emergency exercise requirements clearly were not Intended to disrupt the ^ 
orderly implementation of Improvements in such manner. 

Finally, because granting the request will allow work to proceed without 
disruption, It will result In a net benefit to the public health and safety. 
The NRC has acknowledged that flexibility Is appropriate In applying emergency 
planning requirements. This flexible approach Is especially appropriate in 
this case, where granting the request will facilitate more prompt and 
effective implementation of Improvements. 

For all these reasons, Boston Edison asks that NRC grant the requested 
exemption. In accordance with 10 CFR §170. 12(c), a fee of one hundred and 
fifty dollars ($150.00) will be electronically mailed to your offices. If you 
should require any additional Information In connection with this request, 
please contact either myself or Mr. Ron Varley of my staff (telephone: 617 - 
424-3832). 



ii^4^ 



Ralph G. Bird 
RAL/dlw 



433 



U. S. Nuclear Regulatory Commission 
Page 4 



cc: Dr. Thomas E. Hurley, Director 

Office of Nuclear Reactor Regulation 
U.S. Nuclear Regulatory Commission 
The Phillips Building 
Washington. D.C. 20555 

Mr. R.H. Wessman, Project Manager 
Division of Reactor Projects - I/II 
Office of Nuclear Reactor Regulation 
U.S. Nuclear Regulatory Commission 
7920 Norfolk. Avenue 
Bethesda. MO 20814 

Mr. Richard Krimm. Assistant Associate Director 

FEMA 

500 C Street - Federal Plaza 

Washington, D.C. 20472 

Mr. Edward Thomas 

FEMA - Region 1 

J. W. McCormack Post Office and Court House 

Boston. MA 02109 

Mr. Peter Agnes, Jr. 
Commonwealth of MA 
Assistant Secretary of Public Safety 
1 Ashburton Place - Room 2133 
Boston. MA 02108 

U. S. Nuclear Regulatory Commission 
Region 1 - 631 Park Avenue 
King of Prussia. PA 19406 

Senior NRC Resident Inspector 
Pilgrim Nuclear Power Station 
Rocky Hill Road 
Plymouth. MA 02360 

Henry Vickers, Regional Director 

FEMA - Region 1 

J.W. McCormack Post Office and Court House 

Boston, MA 02109 



434 

The Chairman. Thank you, Attorney General Shannon. Glad to 
see an old friend. 

We'll move right along. I'm pleased to welcome the distinguished 
members of our third panel, representing the various branches in 
state government involved in the Pilgrim restart question. 

I remember the days when the State Secretary of Energy, 
Sharon Pollard, was a freshman legislator; bright and enthusiastic, 
deeply committed to public service, now she has moved onto higher 
office, and I'm delighted that she has the same enthusiasm and is 
an aggressive champion of the public interest in the issues we've 
been discussing this evening. I'm delighted to have her with us. 

Ms. Pollard. Thank you. Senator. 

The Chairman. Our new Public Health Commissioner, Deborah 
Prothrow-Stith, and this is her first public appearance this 
evening, was recently appointed to the position. Commissioner 
Prothrow-Stith will be discussing the important role the Depart- 
ment of Public Health will play in determining what public health 
impacts are associated with Pilgrim Power Plant. We are fortunate 
to have had breakfast with the Reverend Stith this morning, so 
we've been with the family all day. 

Last, but not least. Assistant Secretary of Public Safety, Peter 
Agnes. Peter has perhaps the most difficult job of all because he is 
trying to make an unworkable evacuation plan workable. I'm look- 
ing forward to hearing from him. We'll start with Peter Agnes, left 
to right. 

STATEMENTS OF PETER AGNES, ASSISTANT SECRETARY OF 
PUBLIC SAFETY; SHARON POLLARD, SECRETARY OF STATE OF 
ENERGY; AND DEBORAH PROTHROW-STITH, HEALTH COMMIS- 
SIONER 

Mr. Agnes. Thank you, Mr. Chairman. I'm here on behalf of Sec- 
retary Charles Barry, who by Executive order is the Disaster Coor- 
dinator for the Commonwealth, and also by the Governor's designa- 
tion, is the liaison officer for Massachusetts to the Nuclear Regula- 
tory Commission, and in that capacity, the Secretary is the princi- 
pal point of contact between State officials and the NRC. 

At the outset, I would like to address a point that was made by 
one of the earlier speakers, Ann Waitkus-Arnold, concerning the 
use of potassium iodine, not from a public health standpoint, which 
the Commissioner of Public Health can do, but from a planning 
standpoint. And I want to correct a matter that was referred to in 
her testimony. 

There is no plan today; there has never been to my knowledge a 
plan in the past and there will never be under the Dukakis admin- 
istration, a plan that would leave behind any member of the com- 
munity, be they a special needs person or otherwise, in the event of 
an evacuation by substituting some drug, such as potassium iodine, 
for the safe and secure care of that person. So no one should be 
misled into thinking that there is any thought given to leaving 
anyone behind during an evacuation who would require attention, 
care or evacuation. 

Over the past 2 years, we have taken three major actions to re- 
spond to the health and safety concerns of the Pilgrim nuclear 



435 

power plant. First, we have prepared and filed with the Governor 
two comprehensive written reports, which other speakers here 
have referred to, the most recent of which was released just several 
weeks ago. And we would like to make those reports, which also 
were transmitted to the Nuclear Regulatory Commission and to 
FEMA, a part of the record of these proceedings. 

These reports deal at great length with the history of emergency 
planning activities, both at the State and Federal level, and with 
the many specific problems associated with the Pilgrim plant. It is 
our opinion, to paraphrase the Federal Regulatory Standard, that 
the existing emergency plans for Pilgrim station are not adequate 
to protect the public health and safety in the event of a radiologi- 
cal emergency offsite; and that, therefore, the plant should not be 
allowed to restart unless and until adequate plans are developed, 
tested and approved by FEMA and the other safety related con- 
cerns have been resolved. 

The Chairman. I'm to give you a couple more minutes. 

Mr. Agnes. Thank you. Senator. I have said this on many occa- 
sions and I want to reiterate it tonight, our position has been clear 
and consistent in the past 2 years on this point. And one of the un- 
fortunate things that we — excuse me — that we are facing is the 
lack on the part of the NRC a willingness to make clear precisely 
what corrections or changes it will insist upon in the emergency 
plans before the plant is restarted. 

The second activity we have undertaken is to establish a new di- 
vision in the State within the Civil Defense Agency devoted exclu- 
sively to nuclear emergency preparedness. Despite all of the activi- 
ties that followed Three Mile Island, at the congressional level and 
at the State level, it is only in the last 2 years with an initiative 
taken by Governor Dukakis, that a new division devoted exclusive- 
ly to this purpose has been established and devoted to emergency 
planning problems. 

Third, for the first time again, a planning process has been put 
in place at the State level, which requires work on the part of the 
utility, local government and State government in an effort to de- 
velop adequate emergency plans. 

I would like to conclude my remarks, Mr. Chairman, by com- 
menting briefly, but more specifically on both the progress that has 
been made and also the problems that still remain. 

On the progress side of the ledger, the Boston Edison Co. for the 
first time is a full partner with State and local officials in emergen- 
cy planning. This is evidenced by financial support the company 
has provided to local communities and the fact that it has assigned 
over 20 people to work in the field with State and local government 
to aid in the development of draft plans. Planning resources have 
been invested by the company for the first time to help State and 
local officials and an inadequate emergency communication system 
that was identified in our earlier report has now been replaced by 
the company. 

The company has produced several reports to aid in the emergen- 
cy planning process, including a new evacuation time study that 
was given to the Commonwealth in the fall, and also a study con- 
cerning the adequacy of relying upon only two, instead of the previ- 
ous three reception centers. 



436 

The Chairman. You've got 30 seconds, Peter. 

Mr, Agnes. On the problem side of the ledger, we do have some 
severe problems that remain. We do not, as I indicated earlier, 
have a formally approved plan at this time. We do not have imple- 
menting procedures, which are the key part of the plan, to help 
deal with the evacuation and sheltering of special needs people and 
school children and the infirm and the elderly. The shelter study 
that has been submitted bv the company is inadequate and we are 
insistent that additional wt^k be done. 

The reception center study that we just recently received and 
which is of great concern to residents here in the Plymouth area, 
while useful, is not sufficient in our opinion, and we have deter- 
mined that a third reception center for the Pilgrim plant must be 
sited and we will make a decision in that regard as to a new site 
very shortly. 

In conclusion, I would like to say that on balance, our diagnosis 
is that while the patient has improved; it remains quite ill and the 
prognosis is very uncertain. It remains to be seen, in our judgment, 
whether or not adequate emergency plans for the Pilgrim nuclear 
power plant can be developed, and as many of the speakers here 
before have indicated the only way to insure that the issues that 
we have identified are aired totally and fairly is to hold an adjudi- 
catory hearing before restart. Thank you, Mr. Chairman. 

[The prepared statement of Mr. Agnes follows:] 



437 




Michael S. Dukakis 

Governor 

Charles V. Barry 
Secretary 



^oA/bn, .JLAAacAuAelt^0?y08 f'SflJ 7f7 -7775 



TESTIMONY OF PETER W. AGNES, JR. 

ASSISTANT SECRETARY OF PUBLIC SAFETY 

JANUARY 1, 1988 

GOOD EVENING MR. CHAIRMAN AND MEMBERS OF THE COMMITTEE. I 

AM HERE ON BEHALF OF SECRETARY CHARLES V. BARRY WHO BY 

EXECUTIVE ORDER IS THE DISASTER COORDINATOR FOR THE STATE AND 

BY DESIGNATION OF THE GOVERNOR IS THE LIAISON OFFICER FOR 

MASSACHUSETTS TO THE NUCLEAR REGULATORY COMMISSION. IN THE 

LATTER CAPACITY, THE SECRETARY IS THE PRINCIPAL POINT OF 

CONTACT BETWEEN STATE OFFICIALS AND THE N.R.C. 

THE EXECUTIVE OFFICE OF PUBLIC SAFETY SUPERINTENDS TWO 
STATE AGENCIES WITH RESPONSIBILITY IN THIS AREA— THE DEPARTMENT 
OF PUBLIC SAFETY WHICH LICENSES NUCLEAR POWER PLANT OPERATORS 
AND THE CIVIL DEFENSE AGENCY WHICH IS RESPONSIBLE FOR PREPARING 
AND UPDATING EMREGENCY PLANS. MOREOVER, OTHER AGENCIES AND 
DIVISIONS WITHIN OUR SECRETARIAT WOULD PLAY A VITAL ROLE IN 
RESPONDING TO ANY EMERGENCY AT A NUCLEAR POWER PLANT WHERE 
THERE WAS A PUBLIC HEALTH OR SAFETY IMPACT OUTSIDE THE PLANT. 

OVER THE PAST TWO YEARS, WE'VE TAKEN THREE MAJOR ACTIONS TO 
RESPOND TO THE HEALTH AND SAFETY CONCERNS AT THE PILGRIM PLANT. 

FIRST , WE HAVE PREPARED AND FILED WITH THE GOVERNOR TWO 
COMPREHENSIVE WRITTEN REPORTS, THE MOST RECENT OF WHICH WAS 



438 



TESTIMONY OF PETER W. AGNES, JR. 
ASSISTANT SECRETARY OF PUBLIC SAFETY 
PAGE TWO 

RELEASED JUST SEVERAL WEEKS AGO. I WOULD LIKE TO MAKE THESE 
REPORTS PART OF THE RECORD. THESE REPORTS DEAL AT LENGTH WITH 
THE HISTORY OF EMERGENCY PLANNING ACTIVITIES AT THE STATE AND 
FEDERAL LEVEL AND WITH THE SPECIFIC PROBLEMS ASSOCIATED WITH 
THE PILGRIM PLANT. IT IS OUR OPINION, TO PARAPHRASE THE 
FEDERAL REGULATORY STANDARD, THAT EXISTING EMERGENCY PLANS FOR 
PILGRIM STATION ARE NOT ADEQUATE TO PROTECT THE PUBLIC HEALTH 
AND SAFETY IN THE EVENT OF A RADIOLOGICAL EMERGENCY OFFSITE AND 
THAT THE PLANT SHOULD NOT BE ALLOWED TO RESTART UNLESS AND 
UNTIL ADEQUATE PLANS ARE DEVELOPED, TESTED AND APPROVED BY 
FEMA, AND THE OTHER SAFETY RELATED CONCERNS HAVE BEEN RESOLVED. 

SECOND , WE HAVE ESTABLISHED A NEW DIVISION WITHIN THE CIVIL 
DEFENSE ACENCY WITH FISCAL OVESIGHT WITHIN EOPS DEVOTED 
EXCLUSIVEL/ TO NUCLEAR EMERGENCY PREPAREDNESS. THIS DIVISION 
IS TAKING A LEADERSHIP ROLE WITH LOCAL OFFICIALS AND UTILITY 
EMPLOYEES TO INSURE THAT, UNLIKE IN THE PAST, THERE IS ONLY ONE 
PLANNING PROCESS UNDER STATE SUPERVISION. 

THIRD , WE HAVE ESTABLISHED A FORMAL PLANNING PROCESS TO 
CARRY OUT THE RESPONSIBILITIES ASSIGNED TO US UNDER STATE LAW. 
THE PROCESS INVOLVES THE UTILITY, COMMUNITY GROUPS, AND LOCAL 
AND STATE OFFICIALS MEETING TOGETHER REGULARLY TO ADDRESS 
EMERGENCY PREPAREDNESS ISSUES. IN DOING SO WE HAVE BEEN 
CAREFUL TO UNDERTAKE THIS PROCESS ON BEHALF OF THE THREE 
LICENSED PLANTS THAT AFFECT MASSACHUSETTS--PILGRIM, ROWE , AND 
VERNON — AT THE SAME TIME THAT WE CONTINUE TO ABIDE BY THE 
STATE'S POLICY THAT THERE SHALL BE NO PLANNING FOR THE SEABROOK 
PLANT. 



439 



TESTIMONY OF PETER W. AGNES, JR. 
ASSISTANT SECRETARY OF PUBLIC SAFETY 
PAGE THREE 

I WOULD LIKE TO CONCLUDE MY REMARKS BY COMMENTING BRIEFLY, 
BUT MORE SPECIFICALLY ON SOME OF THE PROGRESS WE HAVE MADE AND 
PROBLEMS THAT STILL REMAIN. 

ON THE PROGRESS SIDE OF THE LEDGER THE BOSTON EDISON 
COMPANY, FOR THE FIRST TIME, IS A FULL PARTNER WITH STATE AND 
LOCAL OFFICIALS IN THE EMERGENCY PLANNING EFFORT. THE UTILITY 
IS INVESTING IN THE PLANNING RESOURCES REQUIRED BY LOCAL AND 
STATE OFFICIALS. THE UTILIITY HAS REPLACED AN INADEQUATE 
EMERGENCY COMMUNICATIONS SYSTEM WITH A MUCH MORE SOPHISTICATED 
AND ENLARGED SYSTEM. THE UTILTY HAS ASSIGNED MORE THAN TWENTY 
PERSONS TO WORK WITH STATE AND LOCAL OFFICIALS AND HAS AIDED IN 
THE DEVELOPMENT OF DRAFT EMERGENCY PLANS WHICH ARE CURENTLY 
BEING REVIEWED BY LOCAL OFFICIALS. THE UTILITY HAS PRODUCED A 
NEW EVACUATION TIME ESTIMATE STUDY THAT WE RECEIVED DURING THE 
SUMMER AND HAS JUST PROVIDED US WITH A STUDY ON THE ADEQUACY OF 
USING ONLY THE TWO EXISTING RECEPTION CENTERS FOR THE EPZ . 
FINALLY THE UTILITY HAS MADE MAJOR CHANGES IN THE MANAGEMENT OF 
ITS NUCLEAR OPERATION AND INVESTED HEAVILY IN AN ON-SITE SAFETY 
ENHANCEMENT PROGRAM. ALSO, IT SHOULD BE NOTED THAT SPECIAL 
TASK FORCES HAVE BEEN ESTABLISHED TO ADDRESS THE SPECIAL NEEDS 
ISSUES AND TO RECOMMEND IMPROVEMENTS IN THE EMERGENCY PUBLIC 
INFORMATION MATERIAL THAT IS DISTRIBUTED ANNUALLY .THESE ARE 
SIGNIFICANT AND POSITIVE DEVELOPMENTS. 



440 



TESTIMONY OF PETER W. AGNES, JR. 
ASSISTANT SECRETARY OF PUBLIC SAFETY 
PAGE FOUR 

SIMILARLY, LOCAL OFFICIALS AND COMMUNITY GROUPS HAVE BEEN 

WORKING CLOSELY WITH THE STAFF OF THE NEW DIVISION OF NUCLEAR 

EMERGENCY SAFETY WITHIN CIVIL DEFENSE IN AN EFFORT TO DEVELOP 

THE BEST POSSIBLE EMERGENCY EVACUATION PLANS. IN MANY CASES, 

THIS EFFORT HAS MEANT THAT LOCAL AND STATE OFFICIALS HAVE 

WORKED NIGHTS AND WEEKENDS WITHOUT COMPENSATION. 

ON THE PROBLEM SIDE OF THE LEDGER, WE DO NOT YET HAVE A 

FORMALLY APPROVED EMERGENCY PLAN TO RESPOND TO AN ACCIDENT AT 

PILGRIM STATION AND IT REMAINS TO BE SEEN WHETHER AN ADEQUATE 

PLAN CAN BE DEVELOPED. THE MOST IMPORTANT AND DIFFICULT PART 

OF THE EMERGENCY PLANS — THE DEVELOPMENT OF IMPLEMENTING 

PROCEDURES FOR PERSONS WITH SPECIAL NEEDS (SCHOOL CHILDREN, THE 

HANDICAPPED, THE INFIRM ETC.) — DO NOT YET EXIST EVEN IN DRAFT 

FORM. QUESTIONS HAVE BEEN RAISED ABOUT THE VALIDITY OF THE 

EVACUATION TIME ESTIMATES ANS WE HAVE DECIDED TO SUBMIT IT FOR 

AN OUTSIDE EVALUATION. THE SHELTERING STUDY PREPARED BY BECO. 

EARLIER IN THE YEAR IS INADEQUATE AND IT REMAINS TO BE SEEN IF 

THERE IS ADEQUATE SHELTER FOR THE POPULATION. A SURVEY OF 

PERSONS WITH SPECIAL NEEDS WAS PREPARED BY BECO. EARLIER IN THE 

YEAR WITHOUT STATE OR LOCAL PARTICIPATION OR APPROVAL AND IS 

INADEQUATE. THE RECEPTION CENTER STUDY WE RECEIVED TWO WEEKS 

AGO IS USEFUL, BUT WE HAVE CONCLUDED THAT A THIRD RECEPTION 

CENTER FOR THE NORTHERN EPZ RESIDENTS IS NECESSARY. WE WILL 

DESIGNATE A SITE IN A SHORT WHILE. 

IN TERMS OF ON-SITE ACTIVITITES, WE ARE TROUBLED BY THE 

DECISION OF THE N.R.C. TO LEAVE UNRESOLVED THE SAFETY ISSUES 



441 

TESTIMONY OF PETER W. AGNES, JR. 
ASSISTANT SECRETARY OF PUBLIC SAFETY 
PAGE FIVE 

PRESENTED BY BOSTON EDISON COMPANY'S PROPOSAL TO INSTALL A 
DIRECT TORUS VENT TO MITIGATE THE CONSEQUENCES OF CERTAIN KINDS 
OF ACCIDENTS INVOLVING THE MARK ONE CONTAINMENT. THE EDISON 
INITIATIVE WAS TAKEN IN RESPONSE TO AN N.R.C. STAFF 
RECOMMENDATION. IN AUGUST, 1987, DR. TOM MURLEY WROTE TO 
BECO.AND ADVISED THEM THAT HE WAS NOT PREPARED TO APPROVE THE 
DIRECT VENT PROPOSAL WITHOUT FURTHER INFORMATION. TO OUR 
KNOWLLEDGE, BECO . HAS NOT SUBMITTED ITS RESPONSE. THIS IS JUST 
ONE REASON WHY OUR CALL UPON EDISON TO PRODUCE THE 
PROBABALISTIC RISK ANALYSIS WE BELIEVE HAS BEEN PREPARED IS SO 
IMPORTANT. 

MANAGEMENT CONCERNS ALSO CONTINUE TO EXIST AT PILGRIM. THE 
MOST RECENT SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 
REPORT (SALP) INDICATES THAT BECO. SCORED LOW IN A NUMBER OF 
SAFETY RELATED CATEGORIES. IN AUGUST, SECURITY VIOLATIONS 
OCCURRED AT THE PLANT THAT ARE THE SUBJECT OF AN ONGOING N.R.C. 
INVESTIGATION. A LOSS OF POWER INCIDENT ON NOVEMBER 12, 1987 
WAS THE SUBJECT OF A RECENT AUGMENTED INSPECTION REPORT. 
ALTHOUGH NO VIOLATION OF REGULATORY REQUIREMENTS WAS FOUND, THE 
REPORT CRITICIZES THE OVERALL MANAGEMENT OF THE RECOVERY AND 
FOUND PLANNING WEAKNESS. 



442 



TESTIMONY OF PETER W. AGNES, JR. 
ASSISTANT SECRETARY OF PUBLIC SAFETY 
PAGE SIX 

ON BALANCE, MY DIAGNOSIS IS THAT THE PATIENT HAS IMPROVED 
BUT REMAINS QUITE ILL AND THE PROGNOSIS IS UNCERTAIN. 

FOR THESE REASONS, IT IS IMPERATIVE, IN OUR JUDGMENT, THAT 
THE N.R.C. HEED THE CALL BY GOVERNOR DUKAKIS AND ATTORNEY 
GENERAL SHANNON TO CONDUCT AN ADJUDICATORY HEARING BEFORE 
CONSIDERING ANY REQUEST TO RESTART THE PILGRIM PLANT. 

I WOULD BE HAPPY TO TAKE ANY QUESTIONS. 

RESPECTFULLY SUBMITTED 



Peter W. Agnes, Jr. 
Assistant Secretary 



443 

The Chairman. Thank you. Sharon Pollard. 

Ms. Pollard. Thank you, Senator. It is nice to be here, and I as 
well would like to thank you for holding this hearing on a subject 
so important to not only the people in and around Plymouth area, 
but certainly to all the people of Massachusetts. 

You've asked for me this evening to speak about the demand for 
Pilgrim's power in meeting Massachusetts' and New England's 
energy situation. While the current supply in the Commonwealth 
of Massachusetts of energy is tight, it is not so tight that the public 
health and safety need be placed at risk with the operation of any 
given power plants, including the Pilgrim nuclear power plant. 

New analyses prepared by the New England Governors' Confer- 
ence and the New England Energy Policy have indicated that New 
England's power needs can be met with existing and planned re- 
sources and potential new resources combined with effective man- 
agement. These analyses have provided evidence that Pilgrim will 
not make or break the electricity supply of New England. 

In Massachusetts, State and utility officials are working to 
assure that power will be available when needed and at a reasona- 
ble cost, both over the short term and the long term. 

Recent accomplishments of State and utility officials will im- 
prove the power supply of the region. For example, the enactment 
of the State appliance efficiency standards last year; a more effi- 
cient building code, so that the buildings we construct in Massa- 
chusetts could be ones that could use energy efficiently. The estab- 
lishment of a cogeneration of small power bidding and development 
process, and the approval by the Energy Facility Siting Council, of 
which I chaired a couple of weeks ago, of a 300 megawatt gas unit 
in Bellingham, MA. These will make substantial contributions to 
the Massachusetts electricity need. 

In addition, current projects will enhance future power planning 
and supply. For example, State officials have requested utilities to 
increase their capabilities to manage load requirements at the time 
of peak demand. The State is also investing ways to fully develop 
conservation, load management and cogeneration at State facilities. 
Furthermore, the Executive Office of Energy Resource and others 
are working with the Department of Public Utilities to establish 
least-cost planning process, which will significantly enhance the de- 
velopment of cost effective, socially beneficial electric resources in 
Massachusetts. 

What I would also like to note is that Pilgrim's past operating 
performance indicates that it cannot necessarily be relied upon to 
provide the power that we need. Pilgrim's lifetime operating per- 
formance is worse than roughly 80 percent of all the other nuclear 
power plants in the country. In the past. Pilgrim has been avail- 
able to produce electricity less than half of the time that it was 
needed. 

In addition, there is not a strong need to operate Pilgrim for eco- 
nomic reasons. While there are many uncertainties as to the eco- 
nomics of future power supplies, a recent analysis indicates that 
Pilgrim may not necessarily provide any economic savings to rate- 
payers if it operates. 

"Therefore, I would like to make it clear that while peak electrici- 
ty resources are currently tight, there is no compelling need to op- 



444 

erate Pilgrim for power supply or econc^nic purposes if it poses an 
unacceptable risk to the health and safety of the people of Massa- 
chusetts. 

As was indicated by my colleagues from the administration, Gov- 
ernor Dukakis has not yet made a determination as to the ultimate 
role which he believes Pilgrim should play, if any. The determina- 
tion will be made only after the issues of plant management, con- 
tainment integrity and evacuation plan adequacy have been re- 
solved. Thank you very much, Senator. 

The Chairman. Thank you very much. Dr. Prothrow-Stith. 

Dr. Prothrow-Stith. Good evening. Senator. Let me start by 
adding my thanks to you for this opportunity. I represent Secretary 
Johnston of the Executive Office of Human Services and the De- 
partment of Public Health as its commissioner. 

We take seriously our responsibilities for the health of the citi- 
zens of Massachusetts, and with regard to the Pilgrim plant we 
have two responsibilities. One has to do with monitoring radiation 
exposure, and the other one has to do with investigation of disease 
outbreaks. 

Relative to monitoring, we are the primary State agency respon- 
sible for radiation control. We have conducted radiation monitoring 
activities in the vicinity of the plant since the mid 1970's. These 
activities include: one, a network of monitoring stations; two, peri- 
odic surveys to determine the extent and seriousness of radiation 
dosage received by humans and animals; and, three, periodic in- 
spections of the power plants itself. 

Our monitoring of radiation includes the dosimeters located at 46 
sites to measure radiation. They are tested quarterly and would in- 
dicate any unusual exposure to radiation among the population 
within 5 miles of the reactor. We also monitor airborne radiation 
at the plant. Water, milk, food, fish, and sediment samples are also 
tested regularly. We conduct weekly inspections of the Pilgrim 
plant, checking internal monitoring and safety protocol. In the 
event of an accident, we would be responsible for a dose assessment 
and for recommendations of appropriate protective actions. 

The department wants to establish a state of the art comprehen- 
sive monitoring program in the vicinity of Pilgrim that could serve 
as an early notification system and insure prompt emergency re- 
sponse in the event of any releases of radioactivity that might 
present a threat to the public health and safety, and also to insure 
adequate monitoring points to measure radiation in the vicinity of 
the reactor. 

The department wants a real time monitoring system which 
would involve the transmission to a State facility of ongoing radi- 
ation levels at selected locations both within the boundaries and 
offsite of the nuclear powerplants. This system, similar to one in 
place in Illinois, would allow the department to know instanta- 
neously when radiation was released into the environment. In addi- 
tion, an on-line data communication link to the state's facilities 
computer would be included in this system. This would allow us to 
know the status of the reactor, that is, the temperature, the pres- 
sure, the water level, et cetera, on a real time basis, as well as fur- 
ther provide early notification of events that could lead to nuclear 



445 

accidents. We believe that this improved monitoring is an impor- 
tant part of a safe evacuation plan. 

Our second responsibility is the investigation of disease out- 
breaks. 

The Chairman. Let me ask you about that monitoring program. 
That is going to cost something, I imagine? 

Dr. Prothrow-Stith. It will cost something. 

The Chairman. Is that going to be a priority for the state or are 
you going to the Federal Government or what? 

Dr. Prothrow-Stith. This is something that at this point, we are 
proposing; it has been proposed in the past and we are in the very 
early stages of a more recent proposal. 

The Chairman. Does Illinois pay for it out of State funds or do 
they get some Federal funding, do you know? 

Dr. Prothrow-Stith. I'm not sure. 

The Chairman. OK. Well, if you might let us know on that. If it 
is done with the States' funds, obviously we'll welcome that. If you 
feel you have to come to the Federal Government, I'll be glad to 
submit 

Dr. Prothrow-Stith. An offer that we would appreciate. [Laugh- 
ter.] 

The Chairman. We'll stop right now, and I'll ask you to stand, if 
you would. [Laughter.] 

Listen carefully. 

[Witnesses sworn.] 

Do you solemnly swear that the testimony you have given and will continue to 
give will be the truth, the whole truth, and nothing but the truth, so help you God? 

The Chairman. Three years of law school. Well, that is a serious 
matter. As you mentioned, the work that is done in Illinois appears 
to be important and significant, and we'd like to know how it is 
going to proceed and hope you keep in touch. 

Dr. Prothrow-Stith. We would like to do that. 

Relative to the investigation of disease outbreaks that might be 
caused by contamination in the environment, we are currently con- 
ducting a study in the Plymouth area into the causes of elevated 
rates of leukemia, a type of cancer that is shown to be caused by 
ionizing radiation. 

We concluded an assessment of the 1982 to 1985 health related 
data for the area around the plant in order to determine the health 
of South Shore residents and how that might be affected by the Pil- 
grim reactor. That assessment showed no unusual statistical trends 
in the patterns of death from cancer or in the frequency of infant 
mortality. Some anomalies in infant mortality and low birth rates 
had been reported. The numbers are so small that it's impossible to 
draw any statistically valid conclusion. 

We did find, however, a statistically significant excess in the inci- 
dents of leukemia among males in the five coastal communities 
surveyed. These elevations are specifically among the types of leu- 
kemia that can be caused by exposure to radiation. 

The incidents of leukemia am.ong females was also elevated, but 
not to the same significant degree. The group should question, of 
course, whether Pilgrim is responsible for the high incidents of leu- 
kemia. At present it is impossible to answer that question, but the 



446 

Department of Public Health is currently conducting two separate 
investigations that may bring us closer to the answer. 

First, we are conducting a case-control epidemiological study to 
help us identify the possible causes of the excess leukemia. In the 
course of this study, we will interview all leukemia cases diagnosed 
since 1982, or their families, in the communities of Plymouth, 
Kingston, Duxbury, Marshfield, and Scituate. We'll take data on 
the places of residence, occupation and medical histories. This in- 
formation will be compared with similar data from people without 
leukemia from the same communities in order to look for any dif- 
ferences. This study will help determine any association between 
leukemia and possible other sources of exposure, such as Benzene, 
chemotherapy, et cetera. 

We must be very frank about the limitations of this study. Epide- 
miology has its limits, especially in cases where we are dealing 
with small populations, relatively small number of cases, small 
doses and small levels of exposure, but if we don't look, we won't 
learn an5^hing at all. 

Second, we're looking into the possibilities that a coastal wind 
pattern may have contributed to the dispersion of radiation emis- 
sion from Pilgrim in a way that bypassed existing radiation moni- 
toring. This work, being conducted through a contract at the Har- 
vard School of Public Health, will determine the feasibility of esti- 
mating the level of radiation reaching the general population. This 
study is up and running and should be completed within the next 
couple of months in its initial phase. 

It is our objective that the combined results of these investiga- 
tions will permit an informed estimate of the contributions of Pil- 
grim emissions to the elevated incidence of leukemia in the vicinity 
of Pilgrim. We would like to work with Dr. Winegarten, if, in fact, 
NIH is very interested in doing some work here. We would be ex- 
cited about that opportunity. 

In summary, we are interested in increasing our monitoring ca- 
pabilities so that you have state of the art capability, and also we 
are very interested in continuing these studies, but as well, partici- 
pating with NIH if that opportunity is available. Thank you very 
much. 

[The prepared statement of Dr. Prothrow-Stith follows:] 



447 




^.-s^y- 



Mlchaal S. Dukakis 
Govamor 

Philip W. Johnston 
Sac rata ry 






150 /Ttv-fTUim/ J^tive/ 

6'/7-7S7-S700 



'^'~™CommlM'I^n,r'**°TESTIMONY OF DEBORAH PROTHROW-STITH , M.D. 
COMMISSIONER, DEPARTMENT OF PUBLIC HEALTH 
JANUARY 7, 1988 

GOOD EVENING MR. CHAIRMAN AND MEMBERS OF THE 
COMMITTEE. MY NAME IS DEBORAH PROTHROW-STITH AND 
I AM COMMISSIONER OF THE DEPARTMENT OF PUBLIC 
HEALTH. 

THE MASSACHUSETTS DEPARTMENT OF PUBLIC HEALTH 
HAS A TWO-FOLD RESPONSIBILITY WITH RESPECT TO THE 
OPERATIONS OF THE PILGRIM NUCLEAR POWER PLANT, 
MONITORING RADIATION EXPOSURE AND INVESTIGATING 
DISEASE OUTBREAKS. 



-FIRST, WE ARE THE PRIMARY STATE AGENCY 
RESPONSIBLE FOR RADIATION CONTROL. WE HAVE 
CONDUCTED EXTENSIVE RADIATION MONITORING 
ACTIVITIES IN THE VICINITY OF THE PLANT SINCE THE 
MID-1970S. THESE ACTIVITIES INCLUDE A NETWORK OF 
MONITORING STATIONS, PERIODIC SURVEYS TO 
DETERMINE THE EXTENT AND SERIOUSNESS OF RADIATION 
DOSES RECEIVED BY HUMANS AND ANIMALS AND PERIODIC 
INSPECTIONS OF THE POWER PLANT ITSELF. 



448 



-2- 

OUR MONITORING OF RADIATION INCLUDES 
DOSIMETERS LOCATED AT 46 SITES TO MEASURE GAMMA 
RADIATION, THE TYPE OF RADIATION WE WOULD FIND. 
THESE DOSIMETERS ARE CHECKED QUARTERLY, AND THEY 
WOULD INDICATE ANY UNUSUAL EXPOSURE TO GAMMA 
RADIATION AMONG THE POPULATION WITHIN FIVE MILES 
OF THE REACTOR. 

THROUGH A COOPERATIVE AGREEMENT WITH THE 
NUCLEAR REGULATORY COMMISSION, WE CONTINUALLY 
MONITOR AIRBORNE RADIATION AT THE PLANT. WATER, 
MILK, FOOD, FISH, AND SEDIMENT SAMPLES ARE TESTED 
REGULARLY. WE ALSO CONDUCT WEEKLY INSPECTIONS OF 
THE PILGRIM PLANT, CHECKING INTERNAL MONITORING 
AND SAFETY PROTOCOLS. 

IN THE EVENT OF AN ACCIDENT, THE DEPARTMENT 
OF PUBLIC HEALTH WOULD BE RESPONSIBLE FOR DOSE 
ASSESSMENT AND FOR RECOMMENDING APPROPRIATE 
PROTECTIVE ACTIONS. 

THE DEPARTMENT WANTS TO ESTABLISH A STATE OF 
THE ART COMPREHENSIVE MONITORING PROGRAM IN THE 
VICINITY OF PILGRIM THAT COULD SERVE AS AN EARLY 
NOTIFICATION SYSTEM AND INSURE PROMPT EMERGENCY 
RESPONSE IN THE EVENT OF ANY RELEASES OF 
RADIOACTIVITY THAT MIGHT PRESENT A THREAT TO 



449 



-3- 
PUBLIC HEALTH AND SAFETY AND ALSO TO INSURE 
ADEQUATE MONITORING POINTS TO MEASURE RADIATION 
IN THE VICINITY OF THE REACTOR. 

THE DEPARTMENT ALSO WANTS A REAL TIME 
MONITORING SYSTEM WHICH WOULD INVOLVE THE 
TRANSMISSION TO A STATE FACILITY OF ONGOING 
RADIATION LEVELS AT SELECTED LOCATIONS BOTH 
WITHIN THE BOUNDARIES AND OFF-SITE OF NUCLEAR 
POWER PLANTS. THIS SYSTEM WOULD ALLOW THE 
DEPARTMENT TO KNOW INSTANTANEOUSLY WHEN RADIATION 
WAS RELEASED INTO THE ENVIRONMENT. IN ADDITION, 
AN ON-LINE REACTOR PARAMETER DATA COMMUNICATION 
LINK TO THE STATE FACILITY'S COMPUTER WOULD BE 
INCLUDED IN THIS SYSTEM. THIS WOULD ALLOW US TO 
KNOW THE STATUS OF A REACTOR, i.e. TEMPERATURE, 
PRESSURE, WATER LEVEL, etc. ON A REAL TIME BASIS, 
AS WELL AS FURTHER PROVIDE EARLY NOTIFICATION OF 
EVENTS THAT COULD LEAD TO NUCLEAR ACCIDENTS. 

- SECOND, WE ARE RESPONSIBLE FOR 
INVESTIGATING DISEASE OUTBREAKS IN THE 
COMMONWEALTH, INCLUDING THOSE THAT MAY BE CAUSED 
BY CONTAMINATION IN THE ENVIRONMENT. WE ARE 
CURRENTLY CONDUCTING A STUDY IN THE PLYMOUTH AREA 
INTO THE CAUSES OF ELEVATED RATES OF LEUKEMIA, A 
TYPE OF CANCER THAT CAN BE CAUSED BY EXPOSURE TO 
IONIZING RADIATION. 



450 



-4- 
TEN MONTHS AGO, THE DEPARTMENT CONCLUDED AN 
ASSESSMENT OF ALL HEALTH RELATED DATA FOR THE 
AREA AROUND THE PLANT IN ORDER TO DETERMINE 
WHETHER THE HEALTH OF SOUTH SHORE RESIDENTS MIGHT 
BE AFFECTED BY THE PILGRIM REACTOR. 

THAT ASSESSMENT SHOWED NO UNUSUAL 
STATISTICAL TRENDS IN THE PATTERN OF CANCER 
DEATHS OR IN THE FREQUENCY OF INFANT MORTALITY OR 
LOW-BIRTHWEIGHT. WHILE SOME ANOMALIES IN INFANT 
MORTALITY AND LOW BIRTHWEIGHT HAVE BEEN REPORTED, 
THE NUMBERS ARE SO SMALL THAT IT IS IMPOSSIBLE TO 
DRAW ANY STATISTICALLY VALID CONCLUSIONS. WE DID 
FIND A STATISTICALLY SIGNIFICANT EXCESS IN THE 
INCIDENCE OF CANCERS OF THE BLOOD-FORMING ORGANS 
AMONG MALES IN THE FIVE COASTAL COMMUNITIES 
SURVEYED. THESE ELEVATIONS ARE AMONG THE TYPES 
OF LEUKEMIA THAT CAN BE CAUSED BY EXPOSURE TO 
RADIATION. THE INCIDENCE OF LEUKEMIA AMONG 
FEMALES WAS ALSO ELEVATED, THOUGH NOT TO THE SAME 
SIGNIFICANT DEGREE. 

THE CRUCIAL QUESTION, OF COURSE, IS WHETHER 
PILGRIM IS RESPONSIBLE FOR THE HIGH RATE OF 
LEUKEMIA. AT PRESENT, IT IS IMPOSSIBLE TO ANSWER 
THAT QUESTION UNEQUIVOCALLY, BUT THE DEPARTMENT 
OF PUBLIC HEALTH IS CURRENTLY CONDUCTING TWO 



451 



-5- 
SEPARATE INVESTIGATIONS THAT MAY BRING US CLOSER 
TO THE ANSWER. 

FIRST, WE ARE CONDUCTING A CASE-CONTROL 
EPIDEMIOLOGIC STUDY TO HELP US IDENTIFY THE 
POSSIBLE CAUSES OF THE EXCESS LEUKEMIA. 

IN THE COURSE OF THIS STUDY, WE WILL 
INTERVIEW ALL LEUKEMIA CASES DIAGNOSED SINCE 
1982, OR THEIR FAMILIES, IN THE COMMUNITIES OF 
PLYMOUTH, KINGSTON, DUXBURY, MARSHFIELD AND 
SCITUATE. WE WILL TAKE DATA ON THEIR PLACES OF 
RESIDENCE, OCCUPATION, AND MEDICAL HISTORIES. 
THIS INFORMATION WILL BE COMPARED WITH SIMILAR 
DATA FROM PEOPLE WITHOUT LEUKEMIA FROM THE SAME 
COMMUNITIES IN ORDER TO LOOK FOR ANY 
DIFFERENCES. THIS STUDY WILL HELP DETERMINE 
ASSOCIATIONS BETWEEN LEUKEMIA AND POSSIBLE 
SOURCES OF EXPOSURE SUCH AS CHEMOTHERAPY AND/OR 
RADIATION THERAPY. 

WE MUST BE VERY FRANK ABOUT THE LIMITATIONS 
OF THIS STUDY. EPIDEMIOLOGY HAS ITS LIMITS, 
ESPECIALLY IN CASES SUCH AS THIS WHEN WE ARE 
DEALING WITH SMALL POPULATIONS, RELATIVELY SMALL 
NUMBERS OF CASES, SMALL DOSES, AND SMALL LEVELS 



452 



-6- 
OF EXPOSURE. BUT IF WE DON'T LOOK, WE WON'T 
LEARN ANYTHING AT ALL. 

SECOND, WE ARE LOOKING INTO THE POSSIBILITY 
THAT COASTAL WIND PATTERNS MAY HAVE CONTRIBUTED 
TO THE DISPERSION OF RADIATION EMISSIONS FROM 
PILGRIM IN A WAY THAT BYPASSED EXISTING RADIATION 
MONITORING. THIS WORK, BEING CONDUCTED THROUGH A 
CONTRACT WITH THE HARVARD SCHOOL OF PUBLIC 
HEALTH, WILL DETERMINE THE FEASIBILITY OF 
ESTIMATING THE LEVEL OF RADIATION REACHING THE 
GENERAL POPULATION. 

IT IS OUR OBJECTIVE THAT THE COMBINED 
RESULTS OF THESE INVESTIGATIONS WILL PERMIT AN 
INFORMED ESTIMATE OF THE CONTRIBUTION OF PILGRIM 
EMISSIONS TO THE ELEVATED INCIDENCE OF LEUKEMIA 
IN THE VICINITY OF PILGRIM. 



453 

The Chairman. Thank you very much, Doctor. We appreciate 
your testimony and your comments. 

Let's move to Ms. Pollard. I know that we're relying to some 
degree on HydroQuebec; is that correct. 

Ms. Pollard. We are receiving — 3 percent of the electricity we 
use in New England is imported from Canada, so right now it is a 
very small percentage. It increases to about 10 percent by the year 
1991. About 10 percent of all the electricity that we use is not con- 
sidered excessive. However, any additional import of electricity 
beyond that would have to be looked at that for that reason, we 
know from past experience that 

The Chairman. Someone mentioned to me, earlier today, about 
the possibility of importing energy from the midwest. 

Ms. Pollard. Yes. 

The Chairman. I'm unfamiliar with both possibilities, the reali- 
ties and the difficulties. 

Ms. Pollard. Very briefly, the governors of New England have 
spoken with some of the Governors in the Midwest that have some 
coal resources within their States. It would work this way. That 
New England ratepayers would bill powerplants in the Midwest, 
that New England ratepayers would put on those powerplants the 
best available control technology to help with our acid rain situa- 
tion. 

It is thought that that energy would still be reasonable in terms 
of the cost to the ratepayers. So there is some thought that you get 
double win from this. That your access is reasonable energy prices 
and that you are also helping with the acid rain situation. There is 
only one problem. You would have to put a transmission line 
through the State of Pennsylvania and through the State of New 
York, and there is some concern that those two States might not be 
thrilled about the idea. 

The Chairman. Let's keep moving on. I'd like to know more 
about it. We'll inquire. You are probably aware of the Department 
of Energy comparing the record of powerplants nationwide, and the 
Department of Energy rated New England 23 out of 26 in its abili- 
ty to keep its plants open from 1983 to 1985. I wonder if you are 
familiar with those findings, and if so 

Ms. Pollard. We are. 

The Chairman [continuing]. What you concluded. 

Ms. Pollard. The Federal Department of Energy has conducted 
that history. We are obviously not pleased with the evidence and 
the information that was presented in that report. We have our 
powerplants not maintained as well as other powerplants in other 
parts of the country; our have a tendency to be down at a more 
frequent rate than in other parts of the country. And we believe 
that part of the problem this past summer was just precisely that. 
When you have one-third of your available electricity down and 
unable to be used, that's what causes you some concern and it may 
cause you some problem. 

We have continued — have in the past, and will continue to en- 
courage the utilities to maintain their plants well and to schedule 
their maintenance at times of the year when we are not experienc- 
ing the greatest demand for electric. 



454 

The Chairman. What is the single most important criterion for 
judging whether or not the Pilgrim plant should be operational? 

Ms. Pollard. The health and safety of the people who live 
within the radius of this power plant and that is the most impor- 
tant criteria that the Governor will consider. 

The Chairman. Doctor, let me ask you how you respond to some 
of the criticism you heard earlier levied against the Department 
concerning its interaction with residents of the local area as well 
as statewide? We know you just recently become the Commissioner 
with responsibilities concerning these difficulties which allegedly 
had existed earlier, but I imagine you had heard of them and were 
concerned about them, and I'm just wondering what kind of reas- 
surance you might be able to give people in the area, and the way 
you might perceive situations? 

Dr. Prothrow-Stith. I think it's important to say that we are 
committed to the health, and the protection of the health, of the 
citizens of the Commonwealth, and as a new commissioner in the 
Department of Public Health, that commitment is something that I 
feel very comfortable reaffirming. 

It is important to say that I think part of the history of the prob- 
lem that we have had has been a situation where some promises 
were made that were not able to be met and perhaps mistakes 
were made. I don't know the details of those histories, but I would 
say very clearly to the citizens here tonight that the commitment 
is strong at the Department of Public Health and we intend not 
only to complete these studies, but to work with the community, as 
we have continued to do in the last few months, in order to make 
sure that the health and safety concerns are addressed. 

The Chairman. Well, I think from what I have known of you, 
the people in this area would have a good sense of your apprecia- 
tion for those concerns and your commitment because I know it 
will be carried forward. 

I think you talked about our request for a study by the NIH. You 
might be helpful to us who are working with the NIH, in terms of 
assistance in the development of that study. I would ask you to do 
that at some time. 

Dr. Prothrow-Stith. What I would like to do, perhaps, is to for- 
ward to you some of the information that — in a cover letter, that I 
could send Dr. Winegarten offering what we currently know in our 
participation. 

The Chairman. A final point. Boston Edison has been identified 
as having a higher rate of worker exposure. Does the Department 
of Public Health have the option of conducting a study of worker 
exposure or is this something that is referred to OSHA. 

Dr. Prothrow-Stith. The Department of Labor has that respon- 
sibility. Edison and the Department of Labor are looking into that 
issue. We would encourage that more be done. It is important, and 
I think the NIH participation may help us with this, to look at na- 
tional data and some international data, as well as worker data, as 
a way to fully appreciate the health risks. So I would encourage 
that more be done, and if we can help in any way, though it is not 
our direct responsibility, we would be willing to do that. 

The Chairman. I want to thank the panel. We had a chance to 
see your full testimony and you covered many additional areas 



455 

which we were interested in. I think this panel has helped us to 
understand better the problems of emergency planning, energy 
supplies, and the public health concerns. We value very much all 
of your testimony. It has been very, very helpful. I know now 
where to go for additional information, so we are grateful to all of 
you. 

Dr. Prothrow-Stith. Senator, may I say one other thing. I just 
learned that the utilities pay for the monitoring system in Illinois. 

The Chairman. I wonder where that little bit of information 
came from. [Laughter.] 

We have a final panel. We want to give them some attention. 
We're going to proceed to that panel. We have been in session for 
three hours. I want you to know this is a very important panel. We 
put great emphasis on it. I would like to have about a 10-minute 
recess, and then we're going to stay here as long as it takes to run 
through the last panel. We want to give them our attention. We 
have important questions, but we want to take our time with that 
panel. They deserve attention. 

You have been a very attentive audience. This has been a very 
informative hearing. We have collected a great deal of information 
and we're grateful to all of those who participated and helped us, 
but since we have been in here for this period of time, we will have 
a 10-minute recess. I know some people have to leave. We're grate- 
ful to them for their presence, but I would hope as many as possi- 
ble would stay. I think this will be an informative session with the 
laist panel. 

[Ten-minute recess.] 

The Chairman. I ask that everybody rejoin us and take their 
seats so we can give our full attention to the final panel. Again, 
you've very attentive. We'll ask that people be kind enough to take 
their seats. 

First of all, we want to thank Nadine O'Neill, and I'm going to 
ask all of you if you will join in giving our wonderful interpreter a 
hand this evening. 

[Applause.] 

The Chairman. She's doing a magnificent job. 

I shall ask our panelists if they will be kind enough to raise their 
hands and do say if 

[Witnesses sworn.] 

The Chairman. We have a few housekeeping details, we have 
statements from some of our colleagues. Representative Studds, 
and Senator Kerry, and we will include their statements in the 
record. I'll indicate to those whose testimony we have not been able 
to receive in person, given the time that's been available to us, 
we'll be glad to receive that testimony. I know that it won't be con- 
sidered as sworn testimony, but nonetheless, it will be valuable to 
us if it is informational, and we will instruct the staff to make that 
part of the testimony which is relevant to this hearing a part of 
the record and we'll leave the record open to the time that the 
Congress comes back in, later in this month. So if there are those 
who have opinions or who have views or who would take differing 
views from what we have heard this evening, who would like to be 
part of the record, they shall be. 

[The statements referred to above follow:] 



456 



STATEMENT OF 

THE HONORABLE GERHY E. STUDDS 

BEFORE THE 

SENATE COMMITTEE ON LABOR AND HUMAN RESOURCES 

January 7, 1988 



I first want to commend Senator Kennedy for holding today's hearing, 
which will focu3 on health matters related to the reopening of Pilgrim 
Nuclear Power Station and the associated issue of emergency evacuation 
planning. I have received dozens of letters from constituents about 
the plant, and it ia clear that these issues are of paramount concern. 

The Pilgrim plant has been shut down since April 1986' because of 
serious questions about safety and management. The Nuclear Regulatory 
Commission's (NRC) most recent evaluation found the facility's 
performance in five significant areas to be minimally satisfactory. In 
addition, the Federal Emergency Management Agency (FEMA) has concluded 
that existing emergency evacuation plans are Inadequate to protect the 
public and could not be implemented until deficiencies were corrected. 
State and local emergency planning officials are working with Boston 
Edison to revise these plans, but this task will not be completed for 
several more months. 

Boston Edison officials have indicated that modifications to the plant 
should be completed by the end of January, and they are expected to ask 
the NRC for restart approval soon after. The agency will then have a 
very important decision to make. 

This determination will be made in the context of an evolving national 
policy on emergency olanning. The critical need for state and local 
government preparedness became obvious in the aftermath of the 1979 
accident at Three Mile island, congress responded by directing the NRC 
to deny a nuclear reactor operating license unless there was reasonable 
assurance that adequate protective measures would be taken in the event 
of an emergency. This past October, In an action with potential local 
Implications, the NRC Issued a rule significantly weakening the 
requirement for state and local participation in emergency planning. 



457 



It Is my view that the NRC would be ignoring its conqressional mandate 
and would be making a grievous mistake if it allowed Pilgrim to resume 
operations before an evacuation plan, acceptable to state and local 
officials, is developed. The NPC commissioners cannot allow pilgrim to 
reopen with a simple statement that they ace satisfied with the 

progress of emergency planning. The citizens of Plymouth and the 
surrounding area must be confident that when the plant's turbines start 
to turn, their local officials will be able to protect their health and 
safety in the event of an accident. Unless there is an approved plan 
in place, they will not have such an assurance. 

If an accident occurs, local emergency planning personnel must be able 
to follow procedures that have been thoroughly and completely 
discussed, reviewed and practiced. Evacuation planning activities, by 
their very nature, cannot be carried out without the close Involvement 
of community officials. Timely warning, effective traffic control, 
evacuation assistance for special populations such as schoolchildren, 
nursing home residents, or the disabled -- all these are essential 
tasks that are uniquely and obviously the responsibility of local 
qov«cnment. *" » 

If the Plymouth plant had a longstandinq history of competent 
management and a flawless operating record, perhaps the details of 
emergency planning would not be so crucial. But Pilarim, characterized 
by many years of mismanagement and numerous regulatory violations, 
demands full attention to this aspect of its operation. 

I want to join other Massachusetts officials in once again stating, 
loudly and clearly, that Pilgrim Nuclear Power Station should not be 
allowed to reopen unles=5 and until all emergency planning, management 
and safety issues hav^ Uien sat i&f actorl jy addressed. 



458 



STATEMENT OF 
SENATOR pHNF.iBRRY 

BEFORE THE 

SENATE LABOR AND HUMAN RESOURCES COMMITTEE 

January?, 1988 



Mr. Chairman, I would like to thank you and the other members of the 
Senate Labor and Human Resources Committee for conducting this important 
hearing tonight. Many of us in Massachusetts have been extremely 
concerned about the safety of this plant and the health effects on the 
surrounding communities around Pilgrim, and this hearing will play an 
important role in the investigation into this problem. 

It is especially important that the Chairman has chosen to conduct this 
hearing, in light of the U.S. Nuclear Regulatory Commission's continued 
refusal to open formal public hearings on the reopening of this plant. Since 
September. Senator Kennedy, Congressman Studds. I and various elected 
officials across the state have requested formal hearings from the N.R.C. on 
the reopening of this plant, to give those who live near this plant an 
opportunity to have their questions answer§d and their concerns raised. 
Once again, in refusing to conduct these hearings, the N.R.C. has not fulfilled 

its regulatory responsibility, and the Oiairman has provided a valuable 
forum for these issues to be addressed. 

The recent history of the Pilgrim Nuclear Power Plant Is one of failure 
and neglert. Served with the largest penalty ever issued by the N.R.C, the 
plant was closed In April. P"' because of repeated failures of its emergency 
tquipmmni tnd for cferof' nagement proM'^ms. The Boston Edison 
Company/ c^ ^^< f^^it year v.uu a j^gir, hBB.ii.iueriaken a managafflent and 



459 



safety review and upgrade program to address these problems. IhejiD 
recent months have reloaded fuel, and hope to have permission to restart 
the plant in the next few months. However, in November of 1987, the plant 
was again beset with safety and health problems, as contaminated water 
exposed workers to radioactive contamination and offsite generator power 
problems occurred, which could have had grave consequences were the plant 
on line at the time. 

There are two fundamental questions that must be addressed before 
this is plant should be allowed to restart: 1 ) are the evacuation plans for the 
communities surrounding this plant adequate, regardless of safety 
improvements that have been made on-site, and 2) is the Nuclear Regulatory 
Commission in the best position to determine whether everything that can 
be done, has in fact been done to improve safety at the plant? 

First, it is my belief that the issue of adequate evacuation plans for the 
communities within a ten mile radius of the plant is still outstanding, and 
that no decision to restart the plant should be made until this issue has been 
fully resolved. Not only have various community civil defense commitlies 
found serious flaws in the plans that Boston Edison has on file, but the 
Commonwealth of Massachusetts has also recently determined that these 
plans are not viable in their current state. Unfortunately, the N.R.C. , in a 
recent rule change, has eliminated the state's role in determining the 
adequacy of evacuation plans, and will allow those plans that have not met 
state criteria to be approved by the N.R.C. Although the Pilgrim Plant went 
on line before the accident at Three Mile Island, and therefore was not 
required to have approved evacuation plans before being granted an 
operating license, the issue of adequate evacuation plans in the event of an 



460 



accident is no less critical. 1 strongly opposed the N.R.C. rule change, and vill 
continue to fight in Congress for the state's role in determining the adequacy 
of evacuation plans. 

I am also seriously concerned about the N.R.C.'8 ability to determine if 
this plant is safe to return to operation. Jhe^role of the U.S. N.R.C. as a 
regulator of the nuclear industry has come under close scrutiny in Congress 

recently, and has led to some disturbing conclusions about the Commission. 
An Investigative Report issued in December, 1987 by the House 
Subcommittee on General Oversight and Investigations concludes that the 
N.R.C. has failed to maintain an arms length relationship with the industry, 
stating that "Over the past several years, the Nuclear Regulatory Commission 
has demonstrated an unhealthy empathy for the needs of the nuclear 
Industry to the detrimp- * of the safety of the American people. " (p. ■41). One 
of th» mott »er!ou -• - "-ised bv ♦h« report is th« so-called "backfit 

rule", which has allowed the N.R.C, to evaluate safety improvements to plants 
already in operation against the cost to the utility to implement them. In 
1986. under the first full year under this rule, the N.R,C. did not impose a 
single plant-specific backfit. and it required only one industry-wide backfit 
which cost utilities less than $8,000 per plant. In opposition to the adoption 
of this rule, former N.R.C. Commissioner James Asselstine concluded, The 
consequence of this rule is to limit the NRC staff's and even the Commission's 
ability to identify and correct safety weaknesses at the nuclear power plants 
in operation and under construction in this country." This rule was struck 
down last August by the U,S. Court of Appeals in D.C. and the N,R,C. issued a 
new proposed rule which eliminates the cost/benefit analysis for those 
improvements necessary for "adequate protection," However, this new rule 
does little to address the problem of vagueness cited by the Court because it 
still does not define "adequate protection," allowing the staff to determine 
that all safety improvements eiceed the adequate protection level and 
therefore can be evaluated in terms of cost to the utility. 



461 



The issue of the N.R.c;s coziness with the nuclear industry causes 
serious concern with regard to the Pilgrim Plant, The N.R.C to date has not 
issued any guidelines in determining whether sufficient safely 
improvements have been made at the plant to allow it to restart. Further, in 
light of the Commission's record on requiring safely improvements to be 
made at any of the nation's nuclear plants, it is almost impossible to have 
confidence in their ability to determine whether sufficient steps have been 
taken. Finally, the N.R.C. has recently decided that, despite documented 
flaws in the design of the Mark I containment vessel employed at Pilgrim, 
they will determine whether Pilgrim should go back on-line without taking 
into account the problem with the containment vessel. All of these decisions 
by the N.R.C, indicate that the public can have little faith in the decision that 
the Commission makes with regard to the Pilgrim Plant. 

For the past two years, because of my concerns over both the 
Seabrook and Pilgrim Nuclear Power plants, 1 and my colleagues in the 
Massachusetts delegation have sought to bring greater accountability to the 
Nuclear Regulatory Commission. The N.RL's tinwillingness to heed the 

advice of the states regarding adequate evacuation plans, and their neglect 
of needed safety improvements at plants currently in operation, have caused 
serious concern in Congress. I will continue to use every opportunity to 
Improve the public accountability of the N.R.C. and again, 1 thank Mr. 
Chairman for conducting these important hearings on this issue. 1 know that 
the testimony presented tonight from residents, state officials, and the N.R.C. 
will add greatly to the debate In Con<?re88, and I look forward to reading the 
testimony presentad here tonight. 



462 



HEALTH SURVEILLANCE OF THE 
PLYMOUTH AREA 



Massachusetts Department of Public Health 
Center for Health Promotion and 
Environmental Disease Prevention 

March 16, 1987 



463 



TABLE OF CONTENTS 



List of Figures i 



Li St of Tab! es i i 



Executive Summary iii 



Scope of the Problem 1 



Mortal ity Data 1 



Incidence 3 



Adverse Reproducti ve Outcomes 8 



Environmental Data 9 



Perspective of the Problem 11 



Conclusion 15 



Figures 



Tables 



Appendices 



464 



LIST OF FIGURES 



Figure 1 Numbers of cases of leukemia, multiple myeloma, and other rare 
cancers of the blood forming organs diagnosed in 1982-84 among the 
residents of Plymouth, by census tract. 

Figure 2 Numbers of cases of leukemia, multiple myeloma, and other rare 
cancers of the blood forming organs diagnosed in 1982-84 among the 
residents of Duxbury, Kingston, Marshfield, and Scituate, by census 
tracts. 

Figure 3 Infant mortality rate in Plymouth, Plymouth County, and 
Massachusetts, 1969-84. 

Figure 4 Percent of low birthweight in Plymouth, Plymouth County, and 
Massachusetts, 1969-84. 



465 



LIST OF TABLES 



Table 1 The numbers of observed and expected breast cancer deaths among 
female residents of Plymouth, the five towns, and the remaining towns of 
Plymouth County for two time periods. 

Table 2 The numbers of observed and expected leukemia deaths among the 
residents of Plymouth, the five coastal towns, and the remaining towns of 
Plymouth County for two time periods. 

Table 3 The numbers of observed and expected incident cases of cancers 
of the hematopoietic and reticuloendothelial system diagnosed among the 
residents of Plymouth and the five towns, 1982-84. 

Table 4a The numbers of observed and expected incident cancers of the 
hemtopoietic and reticuloendothelial system, excluding chronic lymphocytic 
leukemia (CLL), diagnosed among the residents of the five towns, 1982-84. 

Table 4b The numbers of observed and expected incident cases of leukemia, 
all subtypes, diagnosed among the residents of the five towns, 1982-84. 

Table 4c The numbers of observed and expected incident cases of leukemia, 
excluding chronic lymphocytic leukemia (CLL), diagnosed among the 
residents of the five towns, 1982-84. 

Table 4d The numbers of observed and expected incident cases of 
myelogenous leukemia diagnosed among the residents of the five towns, 
1982-84. 

ii 



466 



EXECUTIVE SUMMARY 



Analyses of health data have been carried out to examine whether there is 
excess risk of certain adverse health outcomes among residents in the 
vicinity of the Pilgrim Nuclear Facility located in Plymouth. Five 
communities were studied because of their proximity to the Pilgrim Plant, 
area topography, and coastal meteorological conditions. These communities 
were Duxbury, Kingston, Marshfield, Plymouth, and Scituate. The data 
revealed no disturbing trends in either the patterns of cancer mortality 
or in the expression of low birthweight and infant mortality. Radiation 
monitoring records do not suggest any significant levels of radiation 
off-site of the Pilgrim plant (the levels of radiation residents of the 
surrounding communities are potentially exposed to). However, a 
statistically significant increase in the incidence of cancers of the 
blood forming organs, primarily leukemia, among males in the five coastal 
towns has been identified. The number of leukemia cases diagnosed among 
female residents of the five towns were also higher than expected. 

This descriptive study, as the first step of an epidemiologic 
investigation, has identified the existence of an apparent excess risk of 
cancer of the blood forming organs, particularly leukemia, among the 
residents of the five towns. Major gaps exist in our present 
understanding of the relationship between the occurrence of leukemia and 
the Pilgrim Nuclear Facility. The second step of an epidemiologic 
investigation is to determine the likely cause(s) of the excess risk. 
This data can only be reliably obtained from the cases themselves. 
Additional resources would be required to collect this detailed 

information. 

i i i 



467 



This report presents a review of the health and environmental data for the 
Plymouth area. The data were collected in response to citizen concerns 
over possible health impacts from the operation of the Pilgrim Nuclear 
Facility. 

SCOPE OF THE PROBLEM 

Three analyses have thus far been initiated by the Massachusetts 
Department of Public Health (MDPH) to examine whether there is an unusual 
occurrence of selected adverse health outcomes among the residents of five 
towns - Duxbury, Kingston, Marshfield, Plymouth, and Scituate. These 
communities were chosen because of their proximity to the Pilgrim Plant, 
area topography, and coastal meteorological conditions. 

Since the basic question related to the possible health effects from 
ionizing radiation, the kind of radiation associated with x-rays and 
radioactivity, two of our analyses focused on radiation induced cancers. 
These cancers are leukemia, multiple myeloma, and cancers of the breast 
and thyroid. The third analysis focused on adverse reproductive 
outcomes. All of these health outcomes were chosen because of their known 
or suspected relationship with exposure to low-dose ionizing radiation, as 
reported in current medical literature. Information on these health 
outcomes is routinely collected by MDPH. 

Mortal itv Data 

The first analysis reviewed mortality from leukemia and cancers of the 
breast and thyroid during the period 1969 through 1983. The numbers of 



468 



deaths were determined for the five towns, as well as for Plymouth 
County. The observed numbers of deaths in the five towns were compared to 
the numbers expected based upon state mortality rates adjusted for age and 
population differences. 

Very few thyroid cancer deaths occurred in the five towns and so no 
conclusions could be drawn from that data. Tables 1 and 2 show mortality 
from breast cancer (table 1) and leukemia (table 2) among the residents of 
Plymouth, the five coastal towns combined (Duxbury, Kingston, Marshfield, 
Plymouth, and Scituate), and the remaining Plymouth County towns. These 
data are given for two time periods, 1969-73 and 1979-83. These are the 
years for which complete data on expected numbers of deaths in the five 
towns are currently available. The first time period, 1969-73, 
essentially represents the period before Pilgrim became operational. In 
both time periods, there was a slightly higher number of breast cancer 
deaths observed in the five towns than expected (table 1), but these 
differences were small and statistically not significant. The observed 
mortality from leukemia in both time periods was also slightly greater 
than the expected number among the female population, particularly in the 
town of Plymouth and the five coastal towns combined. Similar excess in 
leukemia mortality was observed among male residents of the town of 
Plymouth, but only during 1969-73. However, all these differences between 
observed and expected mortality were small and statistically not 
significant. Most importantly, the ratios of observed to expected numbers 
of leukemia deaths are similar in both time periods. The ratios would be 
expected to be greater in the later time period if suspected emissions 
from Pilgrim were resulting in increased cancer mortality. Overall, it 
appears that compared to the residents of Massachusetts as a whole. 



469 



individuals living in the five towns probably did not experience excessive 
mortality from these cancers. 

Appendix I shows the numbers of observed and expected deaths from leukemia 
among the residents of all towns within approximately twenty miles of the 
Pilgrim Facility during the two time periods. This data is presented to 
illustrate the number of deaths for each town in the region. These towns 
represent a large geographic area where the potential for exposure to 
emissions from a point source such as Pilgrim would differ greatly among 
the residents. Therefore, an analysis of the area as a whole to explore 
any possible relationship with Pilgrim emissions would be inappropriate. 

Incidence Data 

Cancer incidence, newly diagnosed cases, was reviewed in the second 
analysis. Incidence data were obtained from the Massachusetts Cancer 
Registry, which has collected information on all cancers diagnosed in 
Massachusetts since 1982. Computerized data were available for the years 
1982-84 and all cases diagnosed- in those years were used in this 
analysis. As in the first analysis, the numbers of observed cases were 
compared with the corresponding numbers of expected cases. Cancer 
incidence rates for the whole of Massachusetts were used to estimate the 
expected numbers. 

There was no statistically significant excess of breast or thyroid cancer 
incidence among the residents. of Plymouth or of the five towns combined. 
It should be noted, however, that an excess would not be expected from 
1982-84 incidence data even if there was sufficient exposure from 
radiation to cause cancer. This is because it is estimated that these two 

-3- 



470 



cancers take approximately fifteen years to develop after they are 
initiated by some causal factor like radiation. By 1984, the most recent 
year for which cancer incidence data is currently available, the Pilgrim 
Plant had been operational for less than twelve years. Therefore, it will 
be at least three years, and likely longer, before MDPH will have the 
cancer data to properly assess any possible relationship between Pilgrim 
emissions and breast and thyroid cancer. 

Because of reporting practices of the Cancer Registry, all cancers of the 
hematopoietic and reticuloendothelial systems (cancers of the blood 
forming organs), which include leukemia as well as multiple myeloma and 
some very rare forms of cancer, were reviewed as part of the initial 
incidence analysis. Table 3 shows the incidence of cancers of the blood 
forming organs among the residents of Plymouth and the five coastal towns 
combined, diagnosed between 1982 and 1984. The apparent excess in 
observed incidence in Plymouth is statistically not significant. But when 
the cancers are reviewed for the five towns combined, the number of new 
cases diagnosed among males is significantly (statistically) greater than 
expected based upon state rates. The number of these cancers among 
females was also elevated, but the excess was not statistically 
significant. 

Figures 1 and 2 show the distribution of hematopoietic and 
reticuloendothelial cancer incident cases (cancers of the blood forming 
organs) diagnosed in 1982 through 1984 in the five towns. They appear to 
be distributed throughout the census tracts within the towns. 

As stated above, the cancers of the hematopoietic and reticuloendothelial 
system are comprised of several types of related cancers. The two 

-4- 



471 



principal types are leukemia and multiple myeloma. Leukemia itself is 
characterized by several different subtypes. The major subtypes are 
chronic lymphocytic, acute lymphocytic, acute nonlymphocytic, and chronic 
myelogenous leukemias. Each of these cancer subtypes can be caused by 
certain environmental exposures. But, not all of the same environmental 
causes are related to each subtype of leukemia. For example, exposure to 
ionizing radiation does not appear to be associated with chronic 
lymphocytic leukemia (CLL) but is associated with the development of other 
types of leukemia and of multiple myeloma. With this in mind, the 
analysis of incidence was further focused to examine all hematopoietic and 
reticuloendothelial cancers, excluding CLL. Results were analyzed only 
for the five towns combined because of the small number of cases within 
each town. 

Table 4a illustrates the results of this analysis for the five towns 
combined. The number of cases observed among males between 1982 and 1984 
was again observed to be significantly (statistically) in excess over the 
number expected in the five towns. The number of female cases was also 
elevated but not statistically different from the number expected. In 
other words, there is a reasonable probability that the differences 
between observed and expected numbers among females are due to chance 
alone. 

Ta further refine the analysis, the latency periods was reviewed for each 
of the cancer types and subtypes. Latency period is the length of time 
between initial exposure to the potential cause(s) of the cancer and the 
time when the cancer first becomes detectable (diagnosis). The latency of 
multiple myeloma is at least 15 years. The subtypes of leukemia have 
varying latent periods (2-20 years), frequently dependent upon age at 

-5- 



472 



exposure. Since the latency of multiple myeloma iy likely greater* than 
the ni^mber pf year,$^, Pilprim has been operatjional, leukemia is the 
radiation-sensitive cancer outcome that would have the greatest 
probability of showing an association, using current cancer statistics, 
vHlth %ay..pj»st, Plljgrld ej^issions.. ;. Mj^elogenou.s .lewkeniia^. are. tlw . leukeratas.. . 
most sensitive to induction by radiation. 

Tables 4b through 4d show the number of observed and expected leukemias 
for this more refined analysis. Ten hospitals have been identified as the 
place of diagnosis for the 1982-84 leukemia cases. Four were in Boston 
and the remaining six hospitals represent the major health care centers in 
southeastern Massachusetts. Among males the incidence of each leukemia 
group was consistently elevated. Each elevation is statistically 
significant. The incidence of all leukemia and the subtype myelogenous 
leukemia. among. females was slightly elevated, but. the numbers of observed 
cases were not statistically different from the number expected based upon 
State Incidence figures ► ,.,..../... : • . .- 

One explanation for why the elevation is higher in males than females may 

"•*Brtii«r(h^s •a^''it^9r4at?r >ntc-f6r«p^^^^ 

.leukemia in the five towns. Epldeiniolpgic research has shown that the 
.; lOid^ctipiv of. Uukeniia-ha4..been, .fts^ofUted with ijkimb&cCQf different ....;.. 
• ■factors,' irtcfuding chemicals; certain m^^ aiid * ' ' 

,>> Jtt'* ■*,; '^\A''*^'. '];-^',-':-^'^ ;';''>'-'--*-/^;: ' v;:*^\'^; ;V "■•':■. V^'-'" >V-'^-^;; — ---'-"'^ 
|;Co e^me leiii^lay- «u<^ >':' 

It ma^ bjfr that males in the iFive towns had a greater opportunity for these 

.- rr ~"^' ' _i^_jz,.r."zr.'. -" " ^^.'7 " ~r — i" !"".'' •"";-^- yiiinriiiiipiiiih.-i^ 

occupational exposures, resulting in the higher elevations of leukemia. 
, Another.expUnation may .be that males haid a greater potential for exposure , 
. to air emissions from Pilgrim because of the proximity to the • . 

•• • ..-.6--. . .-, . . 



473 



plant of their residence or place of employment. Without in depth 
knowledge of the type of work the cases performed, where they worked, and 
where they lived, it is not possible to determine the differences in 
potential for exposure between males and females to either occupational 
... cisk. factors for le,ukemia or. air emissions from Pilgrini.. 

Leukemia mortality was not significantly different from that expected, 
whereas leukemia incidence appears to be elevated, particularly among 
males. There are several possible explanations for these inconsistent 
findings. 

One is that survival after the diagnosis of leukemia may be better in the 
five town area than in the state as a whole. This may be due to earlier 
diagnosis, better health care, or better utilization of health care 
facilities. With early diagnosis and treatment, an individual's cancer 
can frequently be controlled or cured. As a result, the individual may 
ultimately die from some- cause unrelated to the cancer and thereby not be 
recorded as a cancer mortality statistic. Incidence would reflect all the 
cancers diagnosed but mortality, therefore, would reflect only those 
''■ canetffr' for Which 'the '^caase of death* happenfed'to be cancer. '' " "-'---•-• 

Another explanatioii may be that the increase in the risk <)f leukemia is 

only recent and; therefore, would only be reflected in current incidence 
' ■■ Istat'lsties. Most can'cfrr deaths occur s'ev^ratyfe^fs after* dfac(nosi s and so 
'C '"igaS niortaTlty would, foV exaraple, incVude many caseSTikety diagnosed 

before 1982, Incidence provides the best indication of current elevated 

if*isks of cancer. 

A third explanation may be that the apparent elevation in leukemia 

-7- 



474 



incidence is due to a chance fluctuation in the observed numbers. Numbers 
of observed cases characteristically increase and decrease from year to 
year. Therefore, these fluctuations are possibly unrelated to any general 
environmental exposures such as air pollution or contaminated drinking 
water. Small numbers, in particular, are frequently susceptible to 
significant fluctuations from year to year that can result in misleading 
differences when compared with expected numbers which are based on larger, 
more stable numbers. 

Appendix II shows the numbers of incident cancers of the hematopoietic and 
reticuloendothelial system (cancers of the blood forming organs) in towns 
within twenty miles of the Pilgrim plant. As with the mortality data 
shown in Appendix I, it would be inappropriate to analyze these towns as a 
group because the potential for exposure to adverse environmental 
exposures would vary greatly from town to town. 

Adverse Reproductive Outcomes 

The third analysis dealt with two adverse reproductive outcomes in the 
Plymouth area, infant mortality and low birthweight. Adverse reproductive 
outcomes often are sensitive though nonspecific indicators of 
environmental problems. Figures 3 and 4 show annual infant mortality 
rates and prevalence of low birthweight among live births in the town of 
Plymouth, Plymouth County, and Massachusetts from 1969 to 1984. (Infant 
mortality is defined as death within the first year of life; and low 
birthweight is defined as birthweight below 2500 grams.) There was an 
obvious, gradual decline in both infant mortality and low birthweight 
rates in each of the three geographical areas before and after the Pilgrim 
plant was operational. The year-to-year fluctuations in the rates, 

-8- 



475 



particularly for (he town of Plymouth, show the susceptibility to 
variation of rates derived from very small numbers of events. For 
example, the 25 percent increase in infant mortality observed in the town 
of Plymouth from 1981 to 1982 is accounted for by an increase in the 
number of infant deaths from four to five. Without these short-term 
fluctuations, the rates for Plymouth Town and Plymouth County appear to 
have been lower than the rates for the State as a whole. 

Environmental Data 

In addition to health studies, MDPH has reviewed radiation data regarding 
the Pilgrim Nuclear Facility. Monitoring of ionizing radiation in the 
vicinity of the Pilgrim Facility has been ongoing since the plant first 
became operational in 1972. This monitoring is carried out by MDPH and 
the U.S. Nuclear Regulatory Commission (NRC), as well as Boston Edison. 
Measurements in the town of Plymouth have been compared with measurements 
from monitoring stations outside the Plymouth area, and suggest that 
radiation levels off-site around the Pilgrim plant have been at or below 
the levels measured elsewhere in the state. 

Additionally, the U.S. Environmental Protection Agency (EPA) and the 
International Atomic Energy Agency (IAEA) have reported on background 
radiation levels for Massachusetts. Background radiation represents the 
amount of ionizing radiation that is normally present in the environment. 
The level for Massachusetts is reported as an average of approximately 13 
microroentgens per hour. Except for one location on the Pilgrim site near 
the stack, radiation levels in Plymouth have essentially been at or below 
background levels for the state. 



476 



Additional environmental radiation data are currently under review by 
MDPH. These include radiation measurement data from lake sediment, 
pasteurized milk, and drinking water. Data from on-site radiation 
monitoring (particularly emissions at the stack), will also be reviewed to 
assess the levdls of on-site radiation emissions over time. 



10- 



477 



PERSPECTIVE OF THE PROBLEM 



Health data reviewed thus far indicate an elevation in the incidence of 
cancers of the blood forming organs, particularly of leukemia, among the 
residents of the five coastal communities studied. This elevation is 
statistically significant among males. No elevation was found for cancers 
of the breast and thyroid, though none would have been expected even if 
there had been sufficient radiation exposure to induce these types of 
cancer. This is because breast and thyroid cancers generally take more 
years to develop after they are initiated by some causal factor like 
radiation than the number of years the Pilgrim plant has been operational. 

The biological significance of the incidence of leukemia in relation to 
possible radiation emissions from the Pilgrim plant cannot be fully 
determined from the available data. No clear pattern or gradient of 
cancers around the plant is apparent. Generally, if some point source, 
such as Pilgrim, is suspected of emitting pollutants then those at 
greatest risk of exposure would be those living closest to the plant. 
Those individuals with the greatest exposure would also be those with the 
greatest risk of disease caused by that exposure. This is because as dose 
of exposure increases, so usually does the frequency of disease 
(dose-response relationship). Therefore, one might expect to see more 
leukemia among those living closest to Pilgrim and less as the distance 
from Pilgrim increases, if emissions are causing leukemia. This was not 
observed. It should be noted, though, that many of the surrounding towns 
are sparsely populated and, therefore, a gradient might be difficult to 
identify. Furthermore, if the ability of radiation to induce leukemia is 



-11- 



478 



approximately the same for widely differing doses of exposure, then a 
gradient might again not be evident. Furthermore, the off-site radiation 
measurement data reviewed so far (the levels of radiation residents of the 
surrounding communities are exposed to) are not consistent with the 
development of adverse health outcomes, based upon current medical 
knowledge. 

Interpretation of the health data currently known for the Plymouth area 
requires a certain understanding of the limitations and value of the data 
before definitive conclusions can be drawn. The Commonwealth has mandated 
the reporting of all new cases of cancer since 1982. On the average, 
there is a six month lag between diagnosis and the report arriving at the 
Massachusetts Cancer Registry, located at and administered by MOPH. The 
reporting hospital is required to report any changes made in the diagnosis 
of cases previously reported to the Registry. 

Additionally, the Cancer Registry regularly conducts quality control 
checks. This process includes checks on the reported diagnosis, as well 
as the completeness of case ascertainment. These quality control 
procedures are in line with the procedures used by cancer registries in 
other states and those supported by the National Cancer Institute, and 
assure the validity of the cancer incidence data. 

Any changes made in the Registry data as a result of these processes often 
result in the revision of incidence rates for specific cancers and for 
specific towns. This has occurred since August 1986 when the Registry 
learned that a female leukemia case in Plymouth had mistakenly been 
reported by a hospital as a male resident of Scituate. The correction of 
this error altered the number of hematopoietic and reticuloendothelial 

-12- 



479 



cancers in the five towns from 32 males and 20 females to 31 males and 21 
females. 

The Cancer Registry data are routinely used for the purpose of 
surveillance. This involves comparing the incidence of specific cancer(s) 
between communities or between communities and the state. The comparisons 
are often complicated by year-to-year fluctuations in the rates due to the 
small numbers of reported cases and the small population size of many 
communities. Consequently, there is often little statistical confidence 
in the observed differences between the incidence rates. Additionally, 
current cancer incidence data are of limited use for assessing time trends 
{to indicate increasing or decreasing incidence rates) in a particular 
community or region because incidence data are presently available for 
only three years (1982-1984). 

Even with stable rates and large populations, descriptive analyses, such 
as that presented in this report, only provide information as to the 
possible existence of a problem and not to the cause(s) of the problem. 
Regarding leukemia in the Plymouth area, a broad spectrum of risk factors 
may have contributed to the observed incidence. 

Occupational exposures, particularly among those who work in the rubber 
and leather industries, have been implicated in epidemiologic research as 
risk factors for leukemia. Exposure to benzene, for example, is a 
documented risk factor for leukemia. Use of certain cytotoxic drugs such 
as chloramphenicol, and radiation received in the course of diagnostic 
tests or treatment are also considered as possible causes of leukemia. 
The past residential histories of cancer cases is also of importance in 
order to determine if there is a relationship between previous residence 

-13- 



480 



of a case and proximity to the Pilgrim plant. Proximity to the Pilgrim 
plant acts as a proxy measure of the potential for exposure and the 
intensity of that exposure. That is, the closer an individual lives to 
the plant, the greater the potential of exposure. Similarly, the length 
of residence acts as a proxy measure for duration of exposure. 

Available information on these important factors is presently limited or 
nonexistent. It is, therefore, not yet possible to establish whether 
there is a cause and effect relationship between the observed leukemia 
incidence and exposure to possible radiation emissions from the Pilgrim 
plant. 



-14- 



481 



CONCLUSION 



These analyses of health data have revealed no disturbing trends in either 
the patterns of cancer mortality or in the expression of low birthweight 
and Infant mortality. Presently, radiation monitoring records do not 
suggest any significant levels of radiation off-site of the Pilgrim plant 
(the levels of radiation residents of the surrounding communities are 
potentially exposed to). However, a statistically significant increase in 
the incidence of cancers of the blood forming organs, primarily leukemia, 
among males in the five coastal towns has been identified. The number of 
leukemia cases diagnosed among female residents of the five towns were 
also higher but not significantly higher than expected. 

This review has established that there is an apparent excess risk of 
leukemia incidence in the five towns combined. But limitations in the 
data available for this investigation preclude an assessment of the 
magnitude of public risk from exposure to air emissions from the Pilgrim 
Nuclear Facility. Major gaps exist in our present understanding of the 
relationship of the nuclear facility with the health status of the 
residents of Plymouth and surrounding communities. The major gaps include 
a full characterization of occupational history, residential history, and 
medical history concerning the leukemia cases. 

In response to concerns regarding the elevated incidence in the 
communities investigated, MDPH has considered several approaches to a 
comprehensive study of the cancer incidence. The objective of the study 
MDPH is committed to conduct will be to overcome the limitations of the 
present health data. This would be accomplished through the collection of 

-15- 



482 



information regarding possible causes of leukemia, including emissions 
from the Pilgrim plant, by means of interviews with cases. The study will 
be designed to include a sufficient number of cases and explore possible 
causes of the observed excess of leukemia in these communities. Such a 
study will require resources that are currently unavailable to MDPH. 



b<>; 



-16- 



483 




residents ot PiymouTn, Tiy census 
tracts 



484 



3 cases 



FIGURE 2 

Number of cases of leukemia , 
multiple myeloma, and other 
rare cancers of the blood 
formins organs diagnosed in 
1982-?4 among the residents 
of Duxbury, Kingston, 
Harshfield, and Scituate, by 
census tracts 



no cases 




485 



CO 







it! 








CO 








Z3 








n: 

















<. 








CO 








CO 








<c 








s 






LU 








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Q 






<c 


^. 






IT 


<c 






>~ 




"^ 




h- 


>-" 


OJ 




1— 1 


i— 


cn 


n 


_J 


^ 


-<^^ 


w 


<: 


ZD 




OS 


1— 


CD 


I 


I— 1 


rr 


U 




I^ 


o 




cn 




2: 


J- 


to 






1 — 


CD 




h- 


ID 


■^-1 




:z 









<: 


S 






Ll_ 


>■ 





H-l Q- 



O 

a. 



CO 

cn 



o 

o 



:3 
o 

>■ 
_J 
a. 



o 



HI 



O 




1 I I I — I — i — I — I — I — I — I — I — I — I — I — I — I — I — i- 



o 

cu 



in o in 



sqiaxg satt 000T/sq3B3a ^ubjui 



1 
1 


CD 


1 




1 


cu 

00 


J 

-1 

( 


CO 


1 



00 


( 

J 


CJ) 



J CD 






J in 

i "^ 

I 

-is 



cn 






o 



J cn 
10 



486 



CD 
n 
LU 



CO 



LU 
CO 

ID 

ni 
o 
<c 

CO 
CO 

<: 



-T 


GC 
CD 


2: 


CD 
O) 


O 

M 
(I' 


O 

_J 


ZD 

o 
o 


1 

CT) 




Ll 
O 


1 — 
ID 


cn 




i— 

•z. 

LU 
O 


o 

:^ 

Q. 






LU 








CL 


nr 

O 

_J- 
CL 





CO 
CO 



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O 

o 



3 
o 
•s. 
>■ 



\ 



3 
o 



L 




(D 



n 

CD 



cu 

CO 



I I I I I I 1 I I I 1 I I I 



-iS 

I 



1 r^ 

j 









I cu 
1 r- 



1 






>- 



oor^tD^nTncu^^o 

sqaaja 3AT1 000l/sni3 0053 woxaq 3q3f3ftq3JTa 



487 



TABLE 1 

The numbers of observed and expected breast cancer deaths among female 
residents of Plymouth, the five coastal towns, and the remaining towns of 
Plymouth county for two time periods. 

1969-1973 1979-1983 

Observed/Expected Observed/Expected 

Plymouth 15/21.5 29/33.2 

Five Towns Combined 56/54.9 84/79.5 



Rest of Plymouth 

County 214/219.6 284/259.8 



Source: Division of Health Statistics & Research, Massachusetts 
Department of Public Health 



488 



TABLE 2 



The numbers of observed and expected leukemia deaths among the residents 
of Plymouth, the five coastal towns, and the remaining towns of Plymouth 
county for two time periods. 







1969-1973 
Observed/Expected 


1979-1983 
Observed/Expected 


Plymouth 


Males 
Females 


6/4.3 

5/3.6 


5/6.9 
7/5.9 


Five Towns 
Combined 


Males 
Females 


8/11.7 
12/9.4 


16/16.3 
16/13.8 


Rest of 
Plymouth County 


Males 
Females 


43/47.3 
47/37.4 


44/54.7 
43/47.1 



\ 

Source: Division of Health Statistics & Research, Massachusetts 
Department of Public Health 



489 



Table 3 

The numbers of observed and expected incident cases of cancers of the 
hematopoietic and reticuloendothelial system diagnosed among the residents 
of Plymouth and the five coastal towns between 1982 and 1984. 

Observed* Expected 

Males 10 7.5 

Plymouth 

Females 7 6.6 

Five Towns Males 31 18.1** 

Combined 

Females 21 15.2 



* Observed numbers reflect corrections reported by hospitals since 
August, 1986 

** Statistically significant difference {p<.05) 



Source: Division of Health Statistics & Research, Massachusetts 
Department of Public Health 



490 



TABLE 4a 



Observed 




Expected 


28 




14.8* 


17 




12.6 




TABLE 


4b 



The numbers of observed and expected incident cancers of the hematopoietic 
and reticuloendothelial systems, excluding chronic lymphocytic leukemia 
(CLL), diagnosed among the residents of the five coastal towns between 
1982 and 1984. 



Males 
Females 



The numbers of observed and expected incident cases of leukemia, all 
subtypes, diagnosed among the residents of the five coastal towns between 
1982 and 1984. 



Males 
Females 



The numbers of observed and expected incident cases of leukemia, excluding 
chronic lymphocytic leukemia (CLL), diagnosed among the residents of the 
five coastal towns between 1982 and 1984. 



Males 
Females 



The numbers of observed and expected incident cases of myelogenous 
leukemia diagnosed among the residents of the five coastal towns between 
1982 and 1984. 



Males 
Females 



Observed 




Expected 


22 




12.1* 


12 




9.3 




TABLE 


4c 



Observed 




Expected 


19 




9.4* 


8 




7.6 




TABLE 


4d 



Observed 


Expected 


13 


5.2* 


6 


4.8 



* statistically significant difference (p<.05) 

Source: Division of Health Statistics & Research, Massachusetts 
Department of Public Health 



491 



Appendix I 
Observed and expected numbers of deaths from leukemia among the residents 
of selected towns in Southeastern Massachusetts, 1969-1973 and 1979-1983 





1969 - 


1973 


1979 - 


1983 




Observed 


Expected 


Observed 


Expected 


Barnstable 
Males 
Females 


3 
3 


4.9 
3.8 


11 
12 


8.0 
7.0 


Bourne 
Males 
Females 


4 
5 


2.1 
1.7 


4 

1 


2.9 
2.1 


Bridgewater 
Males 
Females 


2 



2.2 
1.4 






2.6 
2.1 


Carver 
Males 
Females 




1 


0.5 
0.3 


2 

1 


1.1 
0.7 


Ouxbury 

Males 
Females 


1 



1.5 
1.1 


2 
2 


1.9 
1.5 


East Bridgewater 
Males 
Females 






1.5 
1.1 


1 
1 


1.6 
1.4 


Halifax 
Males 
Females 






0.5 
0.4 


1 
1 


1.1 
0.8 


Hanover 
Males 
Females 


1 
I 


1.3 
1.0 


1 



1.5 
1.2 


Hanson 
Males 
Females 




1 


1.2 

0.8 



2 


1.3 
1.0 


Kingston 
Males 
Females 



2 


1.1 
0.8 


1 
3 


1.4 
1.1 


Marion 
Males 
Females 


1 ' 



0.7 
0.5 


1 
2 


0.9 
0.6 


Marshfield 

Males 
Females 



3 


2.3 
1.7 


5 
3 


3.1 
2.5 



492 



Appendix I (con't) 





1969 - 


1973 


1979 - 


1983 




Observed 


Expected 


Observed 


Expected 


Mashpee 
Males 
Femal es 


1 



0.3 
0.2 


3 




1.0 
0.8 


Middleborough 
Males 
Females 




1 


2.7 
2.3 


2 
3 


3.0 
2.8 


Norwell 
Males 
' Females 


2 
2 


1.0 
0.8 


1 



1.4 
1.3 


Pembroke 
Males 
Females 


1 
1 


1.5 
1.1 


2 

1 


1.8 
1.5 


Plymouth 
Males 
Females 


6 
5 


4.3 
3.6 


5 
7 


6.9 
5.9 


Plympton 
Males 
Females 






0.2 
0.1 






0.3 
0.2 


Rochester 
Males 
Females 


1 



0.4 
0.2 






0.5 
0.4 


Rockland 
Males 
Females 


1 
4 


2.6 
2.1 




2.6 
2.3 


Sandwich 
Males 
Females 






1.0 
0.7 




1.9 
1.4 


Scituate 
Males 
Females 


1 
2 


2.5 
2.2 




3.0 
2.8 


Wareham 
Males 
Females 


2 

5 


2.7 
1.9 




4.4 
3.5 


Whitman 
Males 
Females 


2 
2 


2.2 
1.9 




2.2 
1.9 



493 



Appendix II 
Observed and expected numbers of cancers of the blood forming organs 
diagnosed among the residents of selected towns in Southeastern 

Massachusetts, 1982-1984 







Observed 


Expected 




Ma1e< 


; Females 


Males 


Females 


Barnstable 


12 


13 


11.0 


10.0 


Bourne 


6 


2 


3.8 


3.5 


Bridgewater 


1 


2 


2.7 


1.8 


Carver 


1 





1.7 


0.0 


Duxbury 


3 


2 


1.8 


1.5 ■ 


East Bridgewater 


2 


2 


1.9 


1.6 


Halifax 


1 


1 


1.2 


0.6 


Hanover 


2 


1 


1.5 


1.6 


Hanson 


1 





1.1 


0.0 


Kingston 


3 


2 


1.3 


1.2 


Marion 


1 


2 


1.3 


0.6 


Marshfield 


10 


5 


4.3 


2.6 



494 



Appendix II (con't) 







Observed 


Exoected 




Male: 


; Females 


Males 


Females 


Mashpee 








0.0 


0.0 


Middleborough 


2 


3 


3.7 


2.9 


Norwel 1 


3 


1 


1.2 


1.3 


Pembroke 


1 


2 


1.3 


1.4 


Plymouth 


10 


7 


7.2 


6.8 


Plympton 








0.0 


0.0 


Rochester 





1 


0.0 


0.4 


Rockland 


1 


1 


2.8 


2.2 


Sandwich 


3 





2.3 


0.0 


Scituate 


5 


5 


3.4 


3.1 


Wareham 


4 


2 


3.5 


2.7 


Whitman 


7 


4 


2.5 


1.7 



495 



COMMONWEALTH OF MASSACHUSETTS. JOINT COMMITTEE ON ENERGY 
Testimony of Sidney Cobb MD , March 24, 1987 



Last week I read a paper be-fore the American Epidemiologic 
Society on behalf o-f my coauthors R. W. Clapp, C. K. Chan, h 
Bail us Walter, Jr. In this paper I detailed the information 
leadinq to the conclusion that there is an excess o-f leukemia 
in the five coastal towns north -from Plymouth to Scituate. 
this is now a well accepted conclusion and has been discussed 
befort? this committee and in the newspapers. I will not bore 
you with a repeat of the evidence, but I want to reemphasii-e 
that the excess is very small when compared to the ordinary 
hazards of life. 

T warit to give 'you the reasons that I suspect this excess 
leukemia might be attributable to airborne radioactive 
effluents from the Pilgrim I nuclear powe»r plant. 

1. A closer examination of the residential location of 
the cases reveals that essentially all of the extra 
cases live within four miles of the coast in a strip 
about 20 miles long. 

2. There are several factors which might tend to contain 
the radioactive effluent from the plant in sucli a 
narrow area. The first is the coastal circulation of 
air that is depicted in figure 3. It is easy to 
imagine how an injection of pollutants to the middle 
of such a pattern might be contained and carried along 
the coast. The second is the fact that two to four 
miles inland the land rises rather sharply providing a 
qeoqraphic containing wall '. The third is the fact 
that coastal fogs are not uncommon in this AreA and 
there is new information suggesting that fog can trap 
residues from pesticide spraying. Perhaps it might 
also trap radioactive materials. 

3. Wo3 ha^e examined other possible explanations for this 
very narrow band of excess leukemia and have found 
none satisfactory. There does not seem to be any 
clustering of cases by occupation, and the 
distribution does not fit the distribution of any 
water or milk supply nor is there a known coJ lection 
of toxic waste dumps spread along this coast. 

4. In Maine there is an outbreak of leukemia that is 
similarly located in time and space with respect: to 
the Maine Yankee plant at Wiscasset. This tic=<s as yet 
not been thoroughly investigated because it was 
overlooked by the group who made the original 



496 



investigation o-f leukemia in that sireA. It is, 
howevG'r , quitt? str:iing £<ncl according to data from the 
Maine cancer register appears to be continuing. 

5. Ttiere was a particular peritjd in the early 1 i -f e of tha 
plant during which the radioactive emmissions were 
substantially greater than usual and on morF thari one 
occasion e>;ceeded technical standards. I he worst 
period was the 12 months -from last guarter o-f 19/4 
through the third guarter o-f 1975. See tigure 1. 

6. fhie increase in leukemia appears to have taken place 
about -five years a-fter this period o-f extra emissions. 
Five years is just about the expected incubation time 
-for ra<Jiogenic leukemia. 

7. I -f these releases in 1974--5 were su-f-ficient to 
produce leukemia one would expect to see some adverse 
reproductive outcomes appearing within a -few months o-f 
the exposure. Assuming that the critical period to 
examirie was 1975-6 we proceeded to rank the 26 
health service areas in the state with respect to the 
si^e o-f the bulge i ri that two year period when 
compared with the two years be-fore and the two years 
afterward. The ranking was done -first on infant 
mortality rate (IMR) and second on congenital de-fects 
reported on birth cer ti -f i cates (CDR) . The result is 
shown in table 1 and the maps on the last page o-f the 
handout. The top si;: in the IMR ranking contain the 
top -five in the CDR ranking. All the selected areas 
Sire either north along the coast or adjacent 

to SireA 53 which contains the town o-f Plymouth. Thi« 
distribution is highly unlikely to have occurred by 
chance (P < 0.0002). This -finding clearly needs 
-further exploration, but the hypothesis o-f radiogenic 
health e-f-fects resulting -fro<n the extra emissions -from 
Pilgrim .1 in 1974-5 is suppor-ted. 



'ffc» »*e , the above evidence is quite suggestive enough to urge 
Continuation oi the investigation. A causal relation is -far 
f^-om proven, but the suggestion o-f possible causation should 
receive serious -further consideration. 



rf the investigations to date should be supported by -further 
local research and by -further -findings around other coastal 
rtuclear installations, we will be torced to conclude that m 
the -future the standards must be set low enough to preclude 
releases such as came -from the Pilgrim plant in the middle 
seventies. This would be -facilitated by passage o-f House Bill 
5lBa. 



497 



40 .. 
30 .. 
20.. 



a: 



10 



_ .j\\h- 



MAIN STACK 
All Isotopes 



T-rr-*-!-* 



a_ 









I I I I I I I II 

150 1 



100 



50 



I I I I I I I 

REACTOR BUILDING VENT 
All Isotopes 



I I 



_ wfk-rl 
I I I I 



fln_ 



150 .. 



100 



50 .. 



I I I I I I I I I I 

IODINE - 131 

Main Stack and Reactor Bldg. Vent 



n-h_r 

171 172 |73 174 175 176 1 77 178 1791 80 1 811 82 1 831 84 1 851 861 

YEARS 
(by quarter) 

Fig. 1 Airborne radioactive effluents from Pilgrim I nuclear reactor in 
Plymouth. MA. by quarter. 1972-1986. 

(Source: Boston Edison Semi - Annual Effluent Reports to USNRC) 



498 



FIGURE 3, 




B 



AIR COOLING 
AND DESCENDING 



^ 



t 



-fr 



^r" 




WARM Ain,C.WP». 
WATER l\l5ir<0 



COOLER AIR OVER lArJr 
MOVING Tc/'./aKU 




dill 



Land and sea breezes. 



SOURCE: Field F: Dr. Frank Field's Weather Book. New York: G.P, 
Putnam's Sons, 1981. 



499 



i-iuK 1 Ai . :l T y iiUu i:.orn,i.M t I hl uefeci ka icn 



IWrnlJ I 



KtiNl:. 



I MR 



L.liK 



USA 


RAI 11 


5-3 


I . / 


5-6 


1.6 


5-2 


1.4 


6-1 


1 . 2 


6-3 


1.2 


6-5 


1.2 



HE,A 



5 1 



Kn r 1 (J 
.1 . « 

1 .;j 

1 . B 
1 . 6 
1 . 6 
1 . 5 
'--■-i^i 




r 1 Dure ^ r-lassAchusetts hedi tr-> service arcjae ahoMi mq ttioft 
that *re in vol ved i n the 1975-7& "eoi domic " o* i nt a'tu 
iTtortaiity. I fie areas Mere rar>l:ed bv their t'atio& o4 ii 
(fiOf »:a 1 1 1 V rates *or l97ti-/«i ove?r the I r ratc-s for the Lwo ■, 
;>rcrceedi riQ arid the tMO years toil owi no. The ai >; tOMns tha 
a/-o si.iSdE-J are the top si « in thi s r,ani-i nn 




riqure 3. Hassachuset ts health service areas showing those 
that *re Involved in the 1973-76 "epidemic" o* conaenltai 
defects reported on birth certificates. The areas were ranked 
by their ratios of conqeni tal defects reported in 1975-76 
over those reported for the two years preceedinq and the two 
years .following. The five towns that are shaded are the top 
five in this ranl-lng. (A» can readily be seen they »ro five 
of the %in towns shaded on the previous map) 



500 



USA 


L.i ve 
BirthE. 


ln+ ant 
Observed 


rl E? a t h s 
F.:;pecte 


d* 


Ob 
R 


s/Ev; 
at 1 □ 


P 


N 

E 
D 


umber 
;;ces=i 
eaths 


5-3 


3 . 668 


60 




34.9 






1.7 






25. 1 


5-6 


3 . 932 


73 




45.6 






1.6 






27 . 4 


5 -2 


5,536 


92 




64. 4 






1.4 






27 . 6 


6-1 


2, ;:iil 


.'I 




26. U 






1.2 






4. 2 


6 - :• 


2,973 


39 




33./ 






1 .2 






5.3 


6-5 


3 , 45 .' 


44 




3 7.8 






1.2 






6 . 2 



.; 1,772 3^9 24:...- 93.8 



e,:pecterl number a+ infant deaths calculated by: 
(1. ntant deaths in 1973.74,77,73) 



(livp birttis in 1 973 , 74 , 77 , 7EW 



* (live births in 1975, /6; 



Per ki ns 

30 March 19B7 

Massdat a 



501 



CONGENITAL DEFECTS* - MASSACHUSETTS - 197b ?- 1976 
R«nk HSA 



Li ve 
Births 


Conqeni 
Observe 


tal 


E 


De-f ect 
;;pecte 


d 


«-♦ 


ObB/E:; 
fi: a t X o 


P 


Number 
E;:cess 
De+ects 


2 , 20 1 




29 






1 6 . i;i 






1.3 




1 3 . 


2,978 




26 






14. 2 






l.B 




1 1 .Q 


5 , 536 




55 






31.5 






1.7 




23.5 


3 , 668 




42 






25.8 






1.6 




16.2 


3,457 




35 






22 . 






1.6 




1 3 . i:i 


2,254 




26 






17. 4 






1.5 




8.6 



■t, 6-5 
6 5-1 

Totals 20,094 213 126.9 86.1 



♦ conaenital de-fects recorded on birth cer 1 1 -f i cate'i 



»♦ expected number o-f congenital de-fects Ci^lcul<sted by: 

tconq. defects in 1973,74,77,78) 

e)!p « = ■ » (live births in 1975, 76j 

(live births in 1973,74,77,78) 



Pert 1 ns 

30 March 1937 

Massdata 



502 




BiFIVETOWN. CDR 

INFANT MOFvTALITY AND COWGENI' 



Z April 1937 
-iL DEFECTS - FIVE COASTAL TOWNS - 1970- 



TOWN/VEAR 



Dux bury 
Kinqston 
Mar^h-f i el d 
F'l ytnauth 
Sc 1 tuat e 

Totals 

C DR 



1970 



1971 



1972 1973 1974 
Total Li ve Births 



1975 



1976 



19B4 

19 7 7 



Du;;bury 




124 


109 


131 


123 


124 


114 


104 


125 


l"-i ng^iton 




135 


106 


1 11 


112 


1 1 1 


93 


101 


9'^ 


Marsh fit? 


Id 


292 


307 


271 


311 


299 


268 


2/7 


28o 


PI yinauth 




359 


385 


4u4 


448 


431 


442 


515 


605 


Sci tuate 




248 


200 


178 


193 


161 


18o 


148 


1-5 


Totals 




1 , 158 


) , 1 u7 


1 , 095 


1 . 187 


1 ,126 


1 ,097 


1 , 145 


1 , 290 



Conqeni tal De-fects* 















2 




1 







'J 









1 




1 









2 


1 




T, 




2 




1 




4 







1 




7 




4 




6 




8 




5 


1 









1 




4 




'^ 




1 


2 




lo 




8 




14 




15 




a 


=-, 


9. 


, 13 


6. 


74 


12 


.43 


13 


.6/ 


6. 


,99 


z-.au 



Dux bury 




2 





2 


Ki nqs ton 




2 


3 


3 


Marshf leld 







-z. 


2 


Plymouth 




T; 


b 


5 


Sr.i 1 uate 




4 


jL 


2 


Totals 




11 


13 


14 


IMF< 


9. 


, 5».> 


1 1 .74 


12. /9 



In-fe-nt deaths 




1 


7 





1 


6 


1 


3 


6 



17 



12.64 



15 
13. lo 



6.vg 



congenital de-fects reported on birth certificates 



503 



1978 l'?79 198C.I 1981 1982 1983 19B4 



130 


126 


147 


140 


161 


lti5 


155 


97 


94 


97 


97 


117 


103 


112 


299 


309 


327 


303 


32 1 


304 


329 


551 


590 


594 


552 


588 


558 


575 


175 


182 


194 


IBO 


2i;i9 


201 


"^"^. ■'. 



1 , 252 1 , 30 1 1 , 359 1 , 277 1 , 396 1 , :..:. 1 1 , 4ij4 





1 









1 




4 




1 







1 









2 




2 









1 







2 




1 




4 




1 




1 




1 


':? 




3 




3 




2 




6 




1 




4 


1 




7 




1 




. 




1 




1 




■y 


1. 




3 




6 




8 




11 




7 




9 


4 




16 


4. 


,79 


6. 


15 


8. 


09 


=,, 


.48 


h. 


,45 


3.01 


1 1 , 


. 40 






1 





1 


1 


O 


ij 





u 


2 


4 


2 


1 


7 


-T 


4 


3 


O 








5 


lO 


7 


7" 


■9 


7.09 


5.15 


5.48 



1 



1 



O 1 5 

i i lO 14 

7.a3 /.51 9.9 7 



Perkins 

Source: Mass DPH Annual Reports 



504 



HEALTH SERVICE AREA IV 




'^£>' -^ 



JT^ 



505 



HEALTH SERVICE AREA V" 








*1NCLU)F.S ACTIVE AND INACTIVE SUBAREA COU:;cn,S. 

171 



506 



HEALTH SERVICE AREA VI 




'cp- -d 



172 



507 




I CONOMIC 
I'Kli >kll 11 S 



NEWSLETTER"" 



December. 1986 CEP Publication N86 - 12 



Public Health 



Nuclear Emissions Take Their Toll 

By Jay M. Gould with Brian Jacobs, Celia Chen and Steven Cea 



Chernobyl has raised the universal question ot what 
IS the true impact on public health of nuclear emis- 
sions. This newsletter, the fifth in a series of reports and 
publications by the Council on Economic Priorities on 
the geographic dangers of toxic waste, will review some 
of the evidence linking nuclear emissions in the US to 
increases in mortality rates. 

A state is often too crude a geographic unit for the 
measurement of environmental dangers since these 
dangers are generally local and seldom impact to the 
same degree on all or most localities in a state . As a pre- 
liminary effort, however, statewide and county varia- 
tions in total infant and cancer mortality rates can be 
used to appraise current regional variations in public 
health. 



Economy Determines Mortality 

The advance of any modern industrial society can be 
traced in terms of the systematic decline in its mortality 
rates over time and the consequent increase in the lon- 
gevity of its population. This is true of the US over the 
past two hundred years or more, and certainly so in the 
20th Century when the official mortality statistics 
became representative of the total population. The US 
total mortality rate stood at 17.2 deaths per 1.000 per- 
sons in 1900 and declined at an average annual rate of 
one percent to stand at 8.7 deaths per 1,000 persons in 
1980. The annual decline in mortality rates can, of 
course, be expected to slow as the population ages over 
time. Thus the mortality rate, when adjusted fordiffer- 



The Calculation of Excess Mortality 

Insight into the probable consequences of the Chernobyl disaster can be gained through US Mortality data for areas 
exposed to nuclear emissions, provided the toul volume of curies of radioactive materials released is known . This newslet- 
ter explores the impact on public health of the release (routine and accidental) of some 35 million curies of all noble gases 
and radioactive particulates emitted from all civilian nuclear power reactors in the US in the years 1974- 1981. as tracked by 
ihe Brookhaven National laboratory. Our analysis indicates that such releases (detailed in Table 4) based on mortality data 
for stales most directly affected by such emissions, are associated with nearly 9,000 excess deaths each year 

Brookhaven emissions surveys are extremely conservative. They do not cover emissions from the plulonium producing 
Hanford and Savannah River military reactors. The Atomic Energy Commission has been extremely sanguine about possi- 
ble nuclear contamination of communities situated downwind from military reactors. 

The Portland Oregonian (on May II and 12, 1986) revealed, on the basis of some 19,000 pages of classified data obtained 
as Ihe result of FOIA, that the Hanford military reactors in Benton County, Washington, apparently released into the air 
446.700 curies of radioactive Iodine-131 in the years 1945 to 1950, and an additional 7.616 curies in the years 1951-1961 
This represents staggeringly high radiation levels— only 14 curies of radioactive Iodine were reported to have been released 
by the Three Mile Island disaster in 1979. For example, in an experiment "related to the development of a monitoring 
methodology for intelligence regarding the emerging Soviet nuclear program," Hanford purposely released 5000 curies of 
radioactive Iodine on Dec. 2-3, 1949. One particular stretch of farmland, lying just downwind of Hanford. came to be 
known as "Death Mile." Nine of its ten families have been stricken with cancer since 1950. The full impact of these emis- 
sions on the area affected has never been estimated. It is time for private citizens in the US as well as the USSR and Europe 
to demand official evaluations of the loss of life from nuclear emissions. It is CEP's hope thai the findings and methodology 
offered in this newsletter receive the critical attention of radiation physicists, epidemiologists, and public health 
officials. ■ 



I'." irMi'i; 1*1 .,,■ \i v ^.irl. 



KHMl.i c:i.'i 4. 



Ml- 



508 



Ciiniinued jrim paxe I 
cnces due lo age. declined somewhat 
more -from 178 in 1900 to S y deaths 
fx.-r 1.000 in 1480 

The inlant mortality rate (IMR)— de- 
fined as the number of deaths within the 
first year per 1,000 live births— does not 
require age adjustment and has declined 
much m.)re rapidly Overtime, the IMR 
is very much affected by the change in 
relative health standards of nonwhiles 
since the IMR for nonwhites generally 
has been about 50 percent higher than 
the IMR for all babies. In 1915. the first 
year in which the official Infant mortali- 
ty rate was considered accurate, the 
IMR was 998 The 1980 figure, at 12.6. 
represents an average annual decline of 
3.2 percent over a 65-year period The 
average annual decline in the IMR usu- 
ally ranged between two and four per- 
cent in accordance with the degree to 
which nonwhites and poor whites en- 
joved better health and nutrition in peri- 
ods of economic expansion 

This fact IS indicated by Table 1 w hich 
summarizes trends in infant mortality 
by five-year periods since 1915. Annual 
declines are seen to average below three 
percent in depression years and over 
four percent in the "prosperous" full 
employment war years. In the decade 
1955- 1964. the years when atmospheric 
bomb testing produced peak fallout lev- 
els, the average annual decline slowed to 
one percent, however The signing of the 
test ban treaty in 1963 saw fallout levels 
dropping sharply, and the average rate ol 
decline in the 1965-1979 period was 
again well over four percent 



I Cancer Rates i 

i Steadily Increasing i 

As the overall US mortality rate re- 

, nects the gradual aging of Americans, 
so does the cancer mortality rate— it has 
been increasing for decades But the 
cancer rate is increasing even after ad- 
justment for age and now accounts for 

I about 22 percent of all deaths. , 

These mortality rates, used to evalu- 
ate public health standards, are closely 

; intertwined. Historically, modern 
industrial technology, along with ad- 
vancing medical technology, has ele- 
vated nutrition and health standards. It 
has also contributed greatly to the sys- 
tematic lowering of mortality rates But 

1 over the past three decades, increasing 

1 cancer rates, even after age adjustment . 
represent the grim side of that equation. 

' They reflect in large part the environ- 
mental deterioration accompanying 
modern industrial technology CEP is 

I committed to the exploration of these 
complex and often contradictory eco- 

I nomic. environmental, and public 
health issues 

Infant Mortality 
Linked To Fallout 

! Of the three mortality rates, the IMR 
1 is by far the most sensitive to both eco- 
nomic and environmental change. It 
can respond to a major environmental 
change within months Let us again re- 
fer to Table 1 that summarizes official 
' US IMR data by five-year periods since 
1915. The necessity of including nuclear 
radiation in measures of environmental 
degradation is indicated by the flatten- 



TABLE 1: 


INFANT MORTALITY RATES IN THE US, | 








1915-1979 














Annual % Rates 1 


Year 


A> 


. # Deaths 


per 1,000 Births 


of Change | 


period 


All Babies 


Nonwhite 


All Babies 


Nonwhite 


1975-1979 




144 


22.1 


-4,9 


-4.6 


1970-1974 




184 


276 


-4 2 




1965-1969 




22.7 


.165 






1960-1964 




25,3 


41.6 


■0 9 


-1,0 


I95S-195V 




26.4 


43,7 


-13 


•0 5 


1950- 19S4 




28,1 


44,8 


-36 


-2,2 


1945-1949 




3.V5 


498 


-4,9 


-6.2 


1940^1944 




42 6 


67.2 


-4 6 


-3 9 


1935-I9.19 




53 2 


81 3 


■2 6 


-3 9 


I9.W-I934 




f)04 


986 


-2,7 


-14 


19:5-1929 




69 


105 4 


' -> T 


-1.8 


19211-19:4 




76 7 


115 3 


-4 7 


-5 ■( 


1915-1919 
Stturcc: tV/ti/ Slun. 


95.7 


1497 


- 


— 


IKi oflhr U i 


. 19X0. Viil 11, Mnruihn 


Parr A. Setltnn 2 


hifani Mnrlttht\. 


piiv, 1 













ingoutof the long secular decline in the 
average annual IMR that occurred in the 
bomb test years 

When attention was first drawn to this 
ominous change in the late sixties, pro- 
nuclear proponents asserted this tlat- 
tening out in the annual rate of the de- 
clining IMR merely reflected the natu- 
ral limits of medical technology and the 
possible exhaustion of the powers of an- 
tibiotics. This argument was called into 
question after the ban on atmospheric 
bomb testing by the immediate resump- 
tion of the average annual four percent 
decline in the US IMR, That there are 
such cities as Amsterdam and Yokoha- 
ma today w ith I M R rat los of t he orde r of 
four or five, as against the current US 
IMR of II. indicates we arc still far from 
reaching any "natural" limit 

A 1986 publication ol the ChildrcnV 
Defense Fund has. however, jusi warned 
that another ominous alteration in mtant 
mortality rates has occurred in the peri- 
od 1981 to 1984— when "the annual rate 
of decline has slowed to approximately 
three percent." In this period, the black 
infant mortality rate was also iw ice that 
of white infants, the greatest disparity in 
23 years. (Table I shows that nonwhite 
i.ifanl mortality rates have historically 
been most responsive to both economic 
and environmental changes Average 
annual declines were close to SIX percent 
in prosperous periods such as 1945-49 
and average annual declines less than 
one percent in the peak bomb lest years, ) 
The Children's Defense Fund offers 
much evidence that these recent changes 
can be attributed to cutbacks in Federal 
health, nutrition, and service programs 
The hypothesis that emissions from nu- 
clear reactors are also adversely affect- 
ing infant mortality rates for both white 
and black babies shall be explored 
below 

Most of the nations civilian power re- 
actors came on line in the seventies, par- 
ticularly in 1974 and subsequent years. 
Routine and accidental emissions from 
these reactors have been tracked by the 
Brookhaven National Laboratory 

The following isa summary of the lat- 
est Brookhaven Report: 

Lmi&sions, All Nobte Gases, 
Million Curies 










Total 




1974-1901 


1970-1981 


Riiiling Water 
Reactors 


li.m 


40252 


Pressurized 
Water Reactors 

rmals 


11.687 
J?.4rt 


11.719 



This newsletter investigates the .staiis- 
Coniintietl i><i<!i' 4 



509 



TABLE 2: AVERAGE ANNUAL MORTALITY RATES, 1965^9 AND 1975-82 
BY STATE AND REGION 





> 1 • U 1 , IV! 


t A ( ! '9 


6 5 


19 6 9 




ANNUAL 


A V ! t A 6 


E 1 « 


7 5 


1 9 J ; 


IIAIUS 


l)E CHANCE 




eiBIHS INFANT It! 


•9f MAINS 


Hi CANrm 


cat 


lltlNS INIANI 


INl 


Pof DiAHi 


Nt 


CAN[!R r« 


I8R 


HP 


CNR 




OiA-Ni 


IIH) 




OIAIHS 




OIATHS 




|TN> 






(!A-H) 


tAlli' 


RAIIC 


RAIIO 


»3 


:s'i'0' 


03" 22 5 


■'I.6A4 i«7n2;e 


9 5 


309907 


157 4 


11944)5 


45'.6| 


IS 4 


2:i7''j 


-'.1224 


8 ' 


399011 179.7 


0. 5-6 


'15 


1 141 


Kill* 






































.'O.i ; 


4045 i' 9 


11329 


II'I'.O 


.0 4 


20 '53 


181 2 


!5»02^ 


:;i8 


II : 


12375 


1I0'43 


9 n 


25121 203 8 


561 


867 


1 113 


"ff 


IW? 


'i- H 


'»4 


I0«6« 


II 


HI' 


184 9 


15647 


P5 


9 . 


!i;2 


10)07 


9 3 


2745 201 8 


51- 


839 


1 092 


VK 


:?l^? 


:"41 > N 


..-7 


7260 


10 5 


12112 


195 2 


12589 


116 


9 2 


eo. 


7356 


8 2 


l66l 185 4 


464 


783 


1 001 


If 




154 .' i 


42! 


IV.> 


10 . 


727 


:'2 ^ 


'157 


70 


- 8 


50! 


4380 


3 8 


9|2 182 3 


4-3 


804 


1 057 


IM 


,ii?-. 


|1V 119 


5408 


5''J0A 


n 


10315 


PO ' 


■|961 


7-; 


II 


51)5 


53481 


* 3 


120C1 208 5 


553 


0-84' 


1.093 


•N! 


u»*; 


141 20 .* 


•III 


.|9-, 


10 • 


1-78 


197 3 


11 '86 


170 


14 2 


953 


9221 


9 7 


2151 225 6 


695 


918 


1 143 


"CI 


S01» 


"S 1 H 


2922 


25915 


8 ) 


4832 


165 3 


16685 


435 


II 9 


1107 


2599; 


8 4 


6152 198 


598 


943 


1 197 


mom! »iuHiir 


J4H? 


13720 .: 


36746 


179695 


10 1 


6 7948 


184 9 


48591- 


6710 


II 8 


37008 


1526 '9 


9 5 


'6'»e 207 5 


62- 


0.922 


1 122 


•HT 


JkMS 


'048 22 3 


IF.064 


187700 


10 4 


34171 


189 2 


238206 


1446 


14 5 


177S6 


167766 


- 4 


36670 206 5 


650 


90- 


1 092 


•iij 


IIAUI 


2402 20 9 


6^78 


65102 


9 3 


12405 


177 8 


9IS42 


1129 


12 3 


'174 


64995 


9 8 


1497' 203 1 


390 


945 


1 143 


•p> 


in'e; 


■r'o ?2 1 


11704 


126893 


10 8 


21372 


182 6 


156172 


2134 


13 ' 


11878 


119917 


1 


25141 211 ' 


618 


0.-51 


1.159 


CASr JtumH CEKIML 


7i;9«S 


15692 21 8 


39166 


371057 


9 5 


62907 


160 6 


632173 


9464 


13 4 


4146' 


358145 


6 6 


74396 |7» 4 


613 


-12 


1 117 


■OH 


imti 


3860 20 5 


10503 


99262 


9 5 


16931 


161.2 


163209 


2124 


13.0 


10784 


96324 


9 


20184 137 2 


0.634 


0-45 


1 l6l 


■ IN 


'iiii 


2050 21 • 


SOIS 


4'72B 


"5 


7800 


155.4 


64495 


1066 


12 6 


543' 


4'044 


8.; 


9520 175 1 


575 


-10 


1-126 


■11 


\%i)'- 


4-02 23 9 


13870 


108827 


!0 


18354 


168.9 


176708 


2677 


15 1 


11407 


100416 


8 6 


20-61 183 6 


633 


»'- 


1 086 


Wl 


n2;o: 


3585 22.0 


8581 


74845 


8 ' 


12877 


150 1 


137566 


1878 


11 7 


-I'l 


74149 


8 1 


15421 168 1 


620 


3 926 


1 120 


■Wl 


"ISA 


1484 19.2 


4194 


40394 


"* 


6947 


161 6 


70205 


719 


10 2 


4662 


40210 


9 6 


6309 178 2 


532 


696 


1 076 


UE5I HUlilH CENTRAL 


27«i60 


5543 19.8 


16008 


163935 


10 2 


2680S 


167.4 


271081 


3428 


12.6 


17063 


157578 


9 2 


31462 194 5 


0.636 


-02 


I 102 


•HH 


1.6301 


1235 18 6 


3629 


33527 


* 2 


5762 


158.9 


63172 


728 


11 5 


4029 


33010 


9.2 


6791 168 5 


619 


ki:7 


; 061 


■l» 


(i^o? 


•43 l».3 


2771 


29521 


10 ' 


4830 


174 3 


45090 


507 


113 


2908 


27040 


■' 3 


5518 189 7 


0.594 


875 


1 068 


H'J 


W20 


17S7 21.9 


4575 


52026 


U 4 


8171 


178 6 


'5737 


1148 


15 2 


4830 


49799 10 2 


960- 201 


692 


697 


1 125 


HD 


um 


227 19 1 


633 


56)9 


e 9 


922 


145 6 


12347 


162 


13 1 


651' 


5664 


8 7 


1089 166 8 


686 


0.975 


1 146 


SB 


12009 


261 21 • 


673 


6509 


9 7 


1072 


159 3 


12219 


151 


12-4 


688 


6396 


9 3 


1212 176 1 


56- 


-61 


1 106 


■HI 


251 'A 


410 |6.3 


1449 


14898 


10.3 


2518 


r; 7 


2S871 


323 


12 5 


1563 


14546 


9 3 


2893 185 1 


'68 


9.15 


1 066 


IS 


J5H« 


710 20 2 


2278 


21814 


9 6 


3525 


154 7 


36645 


40' 


11 1 


2542 


21133 


9 


4170 178 


550 


942 


1-151 


sraiH (iiwiic 


5A«05; 


13976 25 5 


29637 


276055 


g j 


42176 


142 3 


520991 


7919 


15 2 


36248 


320918 


8 9 


65682 161.2 


5-7 


951 


1 273 


m 


ID213 


223 21 i 


52) 


4904 


9 4 


780 


148 9 


8961 


118 


13 1 


596 


5040 


3.5 


1116 167 5 


0.603 


0.-05 


1 259 


m 


A2J92 


1426 22.9 


3660 


31342 


8 6 


5565 


152 


51019 


687 


13.5 


4214 


32425 


7 7 


755! 1'9 2 


0-569 


899 


1 179 


■DC 


28530 


673 23 6 


804 


10513 


i: 1 


1480 


184 1 


18163 


442 


24 3 


664 


8715 


15 1 


1764 265 6 


1 031 


1 003 


1 443 


■v» 


71611 


1'6S 24,7 


4547 


373*6 


8 2 


5840 


128 4 


72964 


1036 


14 2 


5285 


40453 


77 


9381 158 6 


0-576 


951 


1 235 


yv 


30526 


752 24.6 


1819 


I960' 


IC 8 


2-50 


|62 2 


29080 


426 


14.6 


1916 


19440 


10 1 


3621 189 


0-594 


941 


1.165 


IKC 


«!«58 


260' 27 7 


5068 


43458 


8 6 


5804 


114 5 


93625 


1307 


15 6 


5775 


47644 


8 3 


'085 157 3 


0.563 


962 


1 574 


■sc 


501 23 


1398 !' 1 


2634 


22066 


8 4 


2919 


110 8 


48484 


930 


1' 1 


3057 


23853 


7.8 


4394 141 7 


el4 


931 


1-297 


•u 


mil 


2320 25 7 


4510 


39555 


8 8 


5423 


120 2 


8'79l 


1294 


14 7 


5345 


43667 


8 2 


7890 147 6 


0.574 


0-52 


1 226 


■fl 


103316 


2H2 25.3 


6071 


67215 


11 1 


11415 


188 


120994 


1780 


14 ' 


-3-6 


99682 


10 6 


21679 232 9 


582 


958 


1-258 


!»s: SDum CEniiui 


2A58I2 


.768 27 5 


12988 


1261)4 


9 7 


17965 


138 I 


232995 


3567 


15 3 


14405 


132058 


9 2 


2499' 173 s 


556 


944 


1 255 


rt 


5»0SA 


:39| 23 6 


3205 


31989 


10 


4817 


150 3 


58376 


727 


12 5 


3603 


32962 


9 1 


6446 179 


529 


9|7 


1 191 


■ IN 


73603 


1858 25 2 


39|9 


38466 


9 » 


5439 


138 8 


6-524 


1078 


IS 5 


4482 


11673 


9 3 


7928 176.9 


614 


0.947 


1.274 


■»l 


65319 


1839 28. 2 


3521 


32S62 


9 3 


4584 


130 2 


59996 


971 


16.2 


3833 


34589 


9 


6567 171 3 


0.575 


0.967 


1,516 


NS 


47836 


1680 35.1 


2343 


22817 


9 7 


3126 


133 4 


45099 


7-2 


17 6 


2487 


22834 


9 2 


.1054 163 


500 


94) 


1 222 


NISI SOUIN CE«I««l 


363118 


8633 23 8 


I90IO 


165622 


8.7 


26363 


138.9 


415029 


5753 


13 9 


23114 


19037! 


8 2 


36606 158.4 


585 


945 


1 141 


■H 


34128 


758 22 7 


1973 


19848 


10.1 


2«0 


151 5 


34761 


461 


13 3 


2241 


21712 


9 7 


4226 188 6 


596 


963 


1 245 


l« 


76263 


2104 27 6 


3663 


33107 


9 


5094 


139 1 


76741 


1234 


16 1 


4118 


35235 


8 6 


6793 164 9 


583 


947 


1 186 


■It 


40468 


869 21 5 


2514 


24370 


9 7 


3995 


158.6 


47463 


620 


13 1 


2958 


27ylO 


9 2 


5297 179 1 


608 


9S2 


1 129 


TI 


2I22S9 


4902 23 1 


10861 


88297 


8 1 


14314 


131 8 


256062 


1438 


13 4 


13797 


106136 


7 7 


20291 147 1 


0.581 


946 


1 116 


HOUNUIH 


155932 


344 7 22 1 


'ti46 


63311 


8 1 


929' 


lie 4 


208613 


2487 


11 9 


10917 


•7254 


7 1 


14425 132 1 


539 


677 


1 116 


Nl 


12346 


269 21 8 


699 


6591 


9 4 


1004 


143 6 


13337 


148 


11 1 


'80 


6519 


8 4 


1227 157 4 


0-510 


887 


1-096 


IB 


12'S2 


251 19 6 


705 


5786 


» 2 


893 


126 7 


19511 


167 


' 


-11 


6362 


7 


1207 132.5 


460 


851 


1 046 


NT 


5823 


128 21 9 


323 


2822 


8 7 


393 


121.7 


8636 


64 


9 7 


442 


3033 


6 9 


530 119 8 


445 


0.786 


0-64 


CO 


38034 


dJN 22 


2019 


17256 


8.5 


2497 


123.7 


46947 


560 


11 9 


2807 


19034 


6 8 


3478 123 9 


542 


7-4 


1 002 


NH 


21«33 


557 25.4 


1004 


700' 


7 


985 


99 1 


24450 


'J'4<i 


12 2 


1264 


8441 


6 7 


1540 121 8 


482 


957 


1 242 


III 


32610 


«5 23.5 


1634 


13204 


6.1 


7043 


125 


4551- 


614 


1! b 


2575 


19985 


7 6 


4001 155.4 


0.575 


960 


1 243 


m 


23661 


432 18 2 


1020 


702) 


6 9 


939 


92 1 


39592 


469 


11 S 


1791 


i;217 


5.9 


1327 95 ; 


649 


856 


1 034 


HV 


8744 


207 23 7 


4A2 


3623 


8 2 


533 


120 4 


11622 


147 


12 6 


745 


5666 


7 6 


Ills 149 6 


531 


-29 


1 ;<2 


PICIEIC 


43205" 


«SS5 19 9 


24114 


206979 


6 6 


35682 


148 


47160- 


5496 


11 7 


29 54- 


231479 


' 8 


49515 l67 6 


586 


9|3 


1 132 


*NA 


53940 


if'i ;• • 


31'0 


2^404 


9 2 


4833 


151 5 


60195 


731 


12.1 


3'4' 


31298 


7 9 


6602 167 2 


611 


860 


1 104 


■l^ 


;3i:c 






;3j;: 


9 5 


3126 


:" !. 


40104 


194 


12 ' 


2*2' 


910" 


■-■ 4 


4^9* I'l 9 


h-)? 


n &'♦, 


1 103 


"C» 


145019 


,664 |i 9 


1»'4I 


158651 


K 4 


27724 


146 4 


371)10 


4271 


11 5 


23028 


179104 


7 9 


38528 166 9 


578 


927 


1 141 


■NWiEii smr; 


INI INIANI NUIALIT 


! SAI! 




Hi 


8U8IAL1II lAI! 






cm 


CANfEI NiiRlAllII RATE 












irfAIHS/HlOii 


• I8IH3I 






ItlAIHS/I.OOO f!«).l"SI 






■SIAIHS/IOO.OOO PEISONSI 









510 



lical relationship between the 35.4 mil- 
ion curies emitted in the years 1974- 
1981 and infant and other mortality rales 
in the years 1975- 1982 in states most di- 
rectly affected. 

For the purpose of this inquiry, the 
contiguous states (excluding Alaska and 
Hawaii) are divided into two groups— 
nuf/carwafe.s (those with power or mili- 
tary reactors) and nonnuclear states 
(those without). Actually, the geograph- 
ic distribution of reactors In the US is so 
wide that only 19 states can be regarded 
nonnuclear. Small states, like the Dis- 
trict of Columbia or Rhode Island, lying 
directly downwind from reactors in ad- 
joining states are included in the nuclear 
group. 

Our definition of nuclear states (des- 
ignated by an asterisk i n Table 2 ) must of 
necessity include Washington and South 
Carolina, home of the Hanford and 
Savannah River military reactors. 
Emissions from these reactors are not 



I reported by Brookhaven, and cannot be 
I assumed to have reached peak levels in 
the late seventies as is the ca.se of civilian 
power reactors. Again, Brookhaven 
does not report on emissions from the 
hundreds of small experimental reac- 
tors located at research institutes, uni- 
versities, and large hospitals. Most of 
these can be found in the stales desig- 
nated in Table 2 as nuclear 

The years 1965-69 were chosen as the 
most suitable control lime period— radi- 
ation from bomb test fallout was at very 
low levels. Both Nevada and Utah, 
which have no nuclear reactors, were in- 
cluded in our nonnuclear states. Some 
residents of both these states, however, 
might have been affected by occasional 
accidental emissions from underground 
tests in the Nevada desert. These tests 
continued without interruption after the 
atmospheric test ban in 1963. In fact, 
these tests are continued today with as 
yet unknown public health consequences. 



The average annual mortality rates 
have been calculated in both lime peri- 
ods for these two groups of slates The 
results are summarized in Tables 3 and 
4 The tables suggest that emissions 
from nuclear reactors in the nuclear 
states may have had a small but statisti- 
cally significant adverse impact on mor- 
tality rates in the 1975-1982 period, 
when such emissions reached high 
levels. 

Thus, according to Table 3, which 
summarizes the rale in the nuclear and 
nonnuclear states, the infant mortality 
rate in the nuclear states was 22.2 per 
thousand births in the 1965-69 period, 
somewhat lower than the national IMR 
in those years of 22.5 (not a statistically 
significant difference). In that same 
period, however, the IMR for nonnu- 
clear states was much higher than the 
nuclear IMR, but ended somewhat 
lower in the later period. Its decline, 
over these years, was at the annual rale 
of 0.89 percent, as against 0.83 percent 



TABLE 3: SUMMARY OF CHANGES 




for the nuclear slates. 

While these differences appear small, 
in Table 4 they translate Into disturb- 
ingly large annual estimates of excess 


IN MORTALITY RATES, 1965-69, 1975-82, 




US, NUCLEAR AND NON-NUCLEAR STATES 












deaths. This calculation yields what the 






NUCLEAR NON-NUCLEAR | 


observed deaths would have been in the 




US 


STATES STATES 




nuclear states if they had had the same 
percentage change in mortality rales ex- 


1965-69 








Total * Infant Deaths 


401995 


310289 


91706 


penenced by the nonnuclear slates. 


Total * Live Birch.s 


17858535 


13989682 


3868853 


A surprisingly similar difference is 


Average Annual IMR 


22.510 


22.180 


23 704 


arrived al between the two groups of 


(Deaths Per 1000 Live Births) 








states with respect to cancer mortality. 


Total * of Deaths 


9351192 


7467466 


1883726 


While the cancer mortality rale in the 


Average Annual Population 


196844 


155742 


41103 


nuclear stales was somewhat below that 


Average Annual Mortality Rate 


950. 1 1 


95896 


91660 


of the nation in the early period, it was 


(Deaths Per 100.000) 








considerably higher in the later period. 


Total * Cancer Deaths 


1549534 


1256809 


292725 


At first glance, this appears surpris- 


.Average Annual Cancer Rate 


157.44 


161.40 


142.44 


ing because we would expect al least a 


(Deaths Per 100,000) 








five-year lag of cancer mortality from 


1975-82 








the year of exposure, suggesting that 


Total * Infant Deaths 


364490 


270823 


93667 


emissions In the 1974-81 period should 


Total * Live Births 


27155479 


20187695 


6967784 


lead to elevated cancer mortality levels 


Average Annual IMR 


13.422 


13.415 


13.443 


In the eighties and nineties. The elevated 


(Deaths Per 1000 Live Birlhs) 








cancer rates In the late seventies may re- 


Total * of Deaths 


15449794 


12157892 


3291902 


flect the much higher but earlier and yet 


Average Annual Population 


222093 


172840 


49253 


unknown emission levels from military 


Average Annual Mortality Rjlc 


869 56 


879.27 


835 45 


reactors. They may also reflect the 


(Deaths Per 100.000) 








emissions from some civilian reactors in 


Total * Cancer Deaihs 


3192087 


2561141 


630946 


the 1970-74 years. 


Average Annual Cancer Rate 


179.66 


185.22 


160 13 


Indeed the impact on public health of 


(Deaths Per 100.000) 








military reactor emissions deserves 


Ratios of Change, 1975-82/ 1965-69 








separate study (See front page box) both 


Infani Mortality Rale 


05963 


06048 


5671 


because the lime period of operation 


Total Mortality Rale 


0.9152 


09169 


9115 


spans several decades, and because the 
cumulated volume of emissions may be 


Cancer Mortality kale 


1 141 1 


1 1476 


1,1242 


Annual I^rcenl Rales of Change 








higher than that of civilian reactors. 


Infani Mortality Ralc 


-4.04 


-3.95 


-4 33 


However, so much Is not known about 


Total Mortality Rale 
Cancer Mortality Rate 


-0.85 
1 41 


-083 
1 48 


-0 89 

1 24 


the treatment and disposal of the huge 
stockpiles of military waste, we must 



511 



assume that the associated public 
health problems may be ol the same 
order of magnitude as those of the 
civilian reactors. 

Unlike mfant and total mortality rates 
that are steadily declining, cancer mor 
tality rates have been rising for several 
decades The causes of this increase in- 
volve a complex mix of environmental 
and demographic factors for which total 
cancer mortality rates, unadjusted for 
sex, race, or age, require considerable 
further research. 

DifTerences in Mortality 

What do these results signify? First, 
the small differences between the mor- 
tality changes of the two groups of states 
cannot be attributed to chance. On the 
other hand, can these differences be at- 
tributed to different nuclear emissions 
levels? There is no clearly defined ten- 
dency evident in Table 2 among each of 
the so-called nuclear states to have 
increases in mortality that exceed those 
of the nation This becomes evident by 
considering the ratios ofchange for each 
state for the three different mortality 
rates shown in Table 2 It can be said that 
a state does worse than the nation if the 
decline in its infant or total mortality 
rate was less than that of the nation or if 
the gain in its cancer mortality rates was 
greater than that of the nation Thus, the 
30 nuclear states have 90 opportunities 
to be measured against the national per- 
formance, and the 19 nonnuclear states 
have 57 such opportunities (As exam- 
ples, the nuclear state of Connecticut 
performed worse than the nation with 
respect to all three mortality rates, and 
the nonnuclear state of Wyoming per- 
formed better on all three counts. ) 

But the nonnuclear states can be seen 
to do better than the nation in only 54 
percent of all cases, and the nuclear 
states do better in about 52 percent of all 
cases. Thus, it cannot be said that non- 
nuclear states have a tendency to per- 
form significantly better than nuclear 
states How can these apparently con- 
tradictory results be reconciled with the 
results of Tables 3 and 4? Can it be that 
the statistically significant differences 
between the two groups of states shown 
by Table 3 reflect factors other than nu- 
clear emissions' There is a simple ex- 
planation of this paradox. 

There are a total of about 90 civilian 
andmilitary reactors that released emis- 
sions of varying volumes in the most re- 
cent time period The effects of these 
emissions will be primarily found in 
residents of those relatively few coun- 



TABLE 4: CALCULATION OF ANNUAL EXCESS 


k 


MORTALITY IN NUCLEAR STATES 1975-82 


1 




NtCLEAR 


NON-NUCLEAR | 




STATES 


STATES 




l%S-69 








Average Annual IMR 


22.18 




23.70 


(Deaths Per KXK) Live Births) 








Average Annual Morlahu Rale 


958.96 




916.60 


(Deaths Per 1(J0,0(X)) 








Average Annual Cancer Rate 


161.40 




142.44 


(Deaths Per lOO.tXK)! 








1975-82 








Average Annual IMR 


12 58 




13.44 


(Deaths Per 1000 Live Binhsl 








Average Annual Moriaiuy Rale 


874 09 




835 45 



181 45 



160.10 



(Deaths Per 100.000) 
Average Annual Cancer Rate 

(Deaths Per 100.000 1 
Actual Avg Annual Infant Deaths 
Actual Avg Annual Live Births 
Actual Avg Annual Deaths 
Actual Avg Annual Population 
Actual Avg Annual Cancer Deaths 
Estimated Avg Annual Infant Deaths 
Estimated Avg, Annual Deaths 
Estimated Avg Annual Cancer Deaths 
Excess Annual infant Deaths 
Excess Annual Total Deaths 
Excess Annual Cancer Deaths 



In ihts table we have calculated the "excess " in mortatitv in the nuclear states as the difference 
in the number (if expected deaths if these states had the same change in morialin- since 1965-69 as 
wflj experienced b\ the nonnuclear states These calculations are warranted by the fact that this 
assumption \ields differences ihai are highly unlikelx ii> be alinhuted tn chance The standard 
deviation ( a ) of the difference between the observed mortaltiy rate and an expected rate' is 
given by the formula: 



33853 


11708 


2523462 


870973 


1519737 


411488 


172840 


49253 


320143 


78868 


31740 


_ 


1510780 


— 


313611 


— 


2113 


_ 


8957 


— 


6532 


— 



Or. 



= / ir.)ll-rj + 

■J .V 



Ir.ld- 



where r, antt r,ure the chser^ed and expfcretl mortahlv rales expressed In \is dettmals on a per 

capita basis, and N represents the number of deaths in the 1975-82 period The results can be 

labulated as follo\cs: 

IMR 

I r, 01342 

r, .01258 

r..-r, .00084 

Or.-r, 00031 

Une 3/Line 4 2 72 

Chance Pmbabilily 004 



CMR 


TMR 


001852 


.008793 


001814 


008741 


000038 


000052 


.00003? 


000037 


1 01 


1 38 


156 


084 



Line 6 indicates the probabilities of securing the observed difference on line 3 purely bv chance 
The difference in infant mortality rates is most significant . for the probability ofgeltinf; as targe a 
difference as ^cis observed is ont\ four out of 1000 lA probability ratio of 50 times out of 1000 is 
lenerulh taken as indicative of a highly improbable result of chance 1 The observed difference in 
cancer mortalin rates lies at the borderline of chance The probability that both the observed 
differences in the infant and cancer mortality could simultaneously be the result of chance could 
be calculated by multiplying .004 by 156 to yield 0006. because these two mortality rates are 
complelely independent The p value for total mortality— 084— lies at the borderline of chance 
probability, but since total mortality includes both infant and cancer deaths (with a joint p of only 
0006). It IS hard to believe that all other deaths would not be affected by the same extra force of 
mortality that affected infants and t anier victims 



ties most directly impacted by the re- 
leases The vital statistics for these 
counties should then shov^ up in these 
counties and not in the far more numer- 
ous remaining counties thul make up the 
United States. 



We do not have emissions data as yet 
for military reactors, which, in any 
case, were in continuous operation in 
both the two time periods we are consid- 
ering We can, however, attempt to de- 
Ctmliiuieil piifte A 



512 



line a nuc/ear county for the SO civilian 
power reactors for which we do have 
emissions data for recent years. 

Some 175 counties have been chosen 
as a first step to defining a nuclear coun- 
ty, one that would be more directly ex- 
posed to recent radioactive emissions 
from civilian reactors These include, in 



addition to the county in which the reac- 
tor is located . an average of two or three 
counties lying within 25 or 30 miles 
from the reactor Those adjacent coun- 
ties lying to the north and east are fa- 
vored in accordance with the prevailing 
wind patterns in the US. (For example. 
it has been suggested that such wind pat- 



terns account for the severity of acid rain 
in the Northeastern region of the US ) 

This too is a highly simplistic defini- 
tion. Windbome emissions by no means 
represent the most important way in 
which nearby residents can be affected. 
For example, rainfall affecting adjacent 
counties probably determines the ulti- 



TABLE 5: NUCLEAR COUNTIES: SUMMARY OF CHANGES 
IN PUBLIC HEALTH MEASURES. 1965-69 AND 1975-82 



NUCLEAR C U H M E S 
BOILING MAIER PRESSUIUZED yilER ALL REACTORS 



MiNNUCLEAR COUNTIES 



REACTORS 



REACTORS 



COUNTIES 



1H5 h9 

)tutti of CounliFS 

mitt' o' lirin-, 

NUltCf of infairl Hfdtti'., 

IHR ;D>>ilns per liioo Birttis) 

NuaDcr if r^lil Deaths 

fHR (Ofitn-, pef 1000 Births) 

PofHiUtion. 1970 
Kuilei of Deaths 
NR lOealhs per 1000 Persofi'J 

»ii»bti of Canter Oedhs 

CNR (Deaths per 100,000 Persohs) 



RATIOS OF CHANGE 

IIIR 

FfIR 

HR 

CNR 



114 



175 



0.632 
0.687 
0.910 
l.MO 



0.599 
0.653 
0.974 
1.230 



0.613 
0.669 
0.942 
1.187 



2968 



0.589 
0.623 
0.922 
1.150 



•fetal Death data relates to the period l'i75-ei. As of this witing, 1962 data are unavailahle 



US luTALS 



3143 



M2574B 


I49M74 


2730406 


IS258«55 


17189341 


.•0524 


32060 


60723 


348023 


«0a746 


23.0 


21 4 


22.2 


22 6 


22.7 


19185 


21256 


39226 


23«246 


276472 


14.5 


14.2 


14.4 


15.7 


15.5 


14552937 


17508052 


31072244 


172232619 


203304863 


6'>3005 


737496 


1387643 


6006837 


9394680 


9.5 


8.4 


6.9 


9.3 


9.2 


117589 


126722 


237103 


1316843 


1553946 


161 6 


144.6 


152.6 


152.9 


152.9 



1975-82 












Ih Curies Eiitted, 1974-91 


2.37E»07 


1.17E*07 


3.54E«07 






tiissioti Per Capita 


1.563 


0.577 


1.035 






Nutber of Births 


1809862 


2305116 


3975794 


23412534 


27388326 


Nutber of Infarit Deaths 


26331 


29542 


54210 


314397 


368607 


I1R (Deaths per 1000 Births) 


14.5 


12.8 


13.6 


13.4 


13.5 


•Nuiber of Births 


1572114 


1987858 


3439066 


20268725 


23707791 


•Nuifcer of Fetal Deaths 


15645 


18412 


33071 


196107 


231178 


•fNR (Deaths per 1000 Births) 


10.0 


9.3 


9.6 


9.8 


9.6 


Population, 1980 


14975515 


20212643 


34166432 


192359373 


226545605 


Nuiber of Deaths 


1037764 


1331493 


2300973 


13185191 


15486164 


NR (Deaths per 1000 Persons) 


8.7 


e.2 


8.4 


8.6 


6.5 


Nuiber of Cancer Deaths 


220776 


289143 


495352 


2707124 


3202176 


CHR (Deaths per 100,000 Persons) 


184.3 


178.1 


181.1 


175.9 


176.7 



0.592 
0.630 
0.925 
1.156 



513 



mate destination of most emitted radio- 
active particulates and effluents Near- 
by residents can also be affected by the 
possible contamination of water, milk, 
and produce from counties even further 
removed from the point source of the 
emissions. Each reactor represents a 
unique geographic situation that de- 
serves a careful examination of wind, 
precipitation and fresh food transporta- 
tion patterns This examination will of- 
fer a more complete definition of those 
adjacent counties vulnerable to local 
emissions. 

Nevertheless, it turns out that even 
with the admittedly restricted definition 
of the 175 nuclear counties used here, 
results indicate adverse impacts on mea- 
sures of infant mortality, fetal mortality, 
total mortality, and cancer mortality in 
the late seventies as compared with the 
earlier period. These results are sum- 
marized in Table 5 which replicates the 
methodology of Table 3. Now. however, 
the change in mortality rates o( nuclear 
counties are compared with nonnuclear 
counties. 

In addition, the nuclear counties are 
separated inlotwo groups: thosecloseto 
boiling water reactors and those close to 
pressurized water reactors. For all nu- 
clear and nonnuclear couMie^, the rales 
for infant, fetal . and total mortality are 
seen to decline over the selected time 
period. It will be seen, however, that the 
declines in nuc/ear counties ineachcase 
fell short of the declines in nonnuclear 
counties. With respect tocancer mortal- 
ity, which has been rising over these 
years, the 19 percent gain in nuclear 
counties exceeded the IS percent gain in 
nonnuclear counties. 

Could such results be the product of 
chance? If the answer is yes. then we 
would expect a 50 percent probability 
for each change in mortality in nuclear 
counties to be worse than the change in 
nonnuclear counties. The chance of 
then getting four such results at the 
same time would be equal to a coin loss- 
er getting four heads in a row. i.e.. 
(.50)'= .0525. or about one in twenty. 
Actually, the probability of obtaining all 
four observed changes in mortality 
rates by chance is less than 2 out of 100 
as evident in the caption to Table 6. 

Given the fact (demonstrated in the 
caption to Table 6) that the difference in 
the mortality experience of the two 
groups of counties is significant, we can 
speculate that there may be two ways to 
increase the statistical significance of 
our findings. The time periods studied 
should be extended and additional nu- 



TABLE 6: THE STATISTICAL SIGNIFICANCE OF 
CHANGING MORTALITY RATES 



IMR 



FMR 



TMR 



CMR 



1. Mortality Rate. Nuclear Counties 

1965-69 
2 Ratio of Change in Nonnuclear 

Count les 
3. Expected Mortality Rale, Nuclear 

Counties, 1975-82(1x2) 

4 Observed Mortalily Rate, Nuclear 
Counues, 1975-82 

5 Difference (4-3) 

6 Standard Deviation of the Difference 

7 5/6 

8. Chance Probability 



02224 014.366 0008933 0.001526 

0.5888 0.62.34 0.9215 I 1504 

0013095 0.008956 008232 0001756 

013635 009616 008413 00181 1 

000540 0.000660 000181 0.000055 

0.000697 0000745 000084 IX)0084 

0.77 89 2 14 65 

0.2207 1867 0162 2579 



In this table, we are testing the differences between a mortaliri' rale renistereii in the unnhineil 
group of I ?5 nuclear utttnties in tV75-82 with wluil wiiuld have been expelled if these amniies 
had the same change in inonaliry experienced b\ alt the nonnuclear t nunties H> kniiw from 
Table 5 that these counties had a somewhat heller performance with respect to all (our nioittihn 
rates 

For the Mike of precision, we base expressed all rates im a per-capila husis lo six decimals 
For example the IMR of the nuclear counties would have been Ol.iM.'- instead ol 01J6J5 if its 
1^65-W rale had undergxtne the lame ratio of change (.38il3l repi'rled for the nonnuclear loiin- 
lies. Is the difference between this 'expected ' ' rule and the observed actual rate 1 0(105 40t 
significant? The answer is given by the formula for the standard deviation i a t of the 
difference between two sample rales: 



r,- r. =l (r,) II -r.) + (r.l 1 1 -~l 
"in n 



where r, is the expected rate, ri is the observed rate, and n is lite number of deaths involved in 
the calculation of the monalitv rate 

If'f see from rows 6, 7 and 8 above that the pntbabilirv of securing h\ chance alone a diver- 
gence between the expected and observed IMR as great or greater than . 0(10540 is aboui 22 
percent Bx' itself, this cannot be regarded as a significant divergence Similarlx . the ' i hance 
probabilities of securing the obserx-ed divergences m the fetal and cancer morialilv ratcx are 
respectively 19 percent and 26 percent, each being high enough to be regarded ax the pnssihle 
product of chance But since each of these three rales are comfilciclx oulepeiidcni . wc can ask 
what is the probabilitv thai all three divergences are simultaneously the product ofihuncc' The 
answer, given bx multiplying the three independeill probabititiex tx .0106. which is about one 
chance in one hundred. 

This is in agreement with the vers low chance probability t.0162) of securing the ohserxed 
divergence in the total monalirv rale, which of course includes infant, fetal, and cancer deaths 
Thus, we haxe two pieces of evidence lo suggest thai there are less than two chancer out o( one 
hundred for the following statement to be false In the period I97s~82 there txas xome exln. (one 
of mortality present in the nuclear counties not opermmg m ihe ntinnuclcar * ouiilics 



clear counties included. Extending the 
definition of nuclear counties possibly 
affected by radioactive rainfall might, 
for example, double the number of 
deaths involved. If Ihe divergence be- 
tween observed and expected rales re- 
mained the same, the significance of Ihe 
results would be increased by 40 percent 
(i.e.. by yi). 

If the more current experience in Ihe 
eighties is included, more significant di- 
vergences in the cancer rales can be ex- 
pected. Based on only a few years in the 
early seventies, the cancer rale diver- 
gence in Table 6 is seen to be the least 
significant, if nuclear emissions in the 
seventies do result in elevated cancer 
rales, such effects will more likely be 
seen in the next twenty years. 



A more detailed, properly financed 
study w(3uld, of course, try lo account 
for other environmental factors and al- 
low for adjustments for changes in age. 
sex, and race required by proper bio.sta- 
tistical procedures. These results, in 
CEP's opinion, would illuminate the 
main thrust of these findings. 

It is clear that emissions in the nuclear 
counties have had an adverse impact on 
mortality, particularly on Ihe very 
young and very old It will be noted that 
Ihe total mortality rate (TMR) regis- 
tered in the nuclear counties had the 
smallest likelihood of boinp due to 
chance. This rate mainly reflects the 
deaths of persons over 65 years of age. 
But infant and fetal deaths arc alinoM 
Continued pane V 



514 





TABLE 7: REACTORS AND LOCATIONS 




TOTAL 








REAcroa 


B/P EHISSIOHS 


LOCATION 


COUNTIES INCLUDED | 




1974-61 








lig Rock Point 


B 3.34E»05 


4 iiles NE of Charlevou, ni 


HI; 


CharlevoH, Chetoygan, Ettett 


Iromi's Ferry 


B 1.04E«06 


10 iiles Ml of D«catur, Al 


AL. 


Laurence, Hadison, Horgan IN: Franklin, Lincoln 


trunsvick 


B 1.0«E«IK 


20 iiles S of NiliinQton, NC 


NC: 


Duplin, Net Hanover, Onslot, Pender 


Cooper 


B 1.03£»05 


70 iiles S of Ouha. NB 


lA: 
NI: 


Fretont, Hills 

Cass, 'Douglas, Lancaster, 'Sarpy, 'Nashington 


Crnden 1,2(3 


B 3.9;E»06 


14 iiles SN of Joliet, IL 


IL: 


Cook, DuPage, lendall, Nill IN: Lake 


Duane Arnold 


B 2.42Et04 


8 iiles NN of Cedar Rapids, U 


lA: 


Benton, Buchanan, Delanare, Dubuque, Linn 


fdnin I. Hatch 1 1 2 


B 7.47E»04 


11 iiles N of lailey, U 


GA: 


Appling, Candler, latnall, Tootbs 


Huiholdt Bay 


B 9.62E«05 


4 iiles SN of Eureka, CA 


CA: 


Del Norte, Hutboldt, Siskiyou, Trinity 


Jttes 4. Fitipatrick 


1 3.58E»05 


U iiles N of Syracuse, NT 


NT: 


Jefferson, «Osiie90, St. Laurence 


La Crosse 


B 3.0IE«05 


19 iiles S of La Crosse, NI 


NI: 


Buffalo, Jackson, La Crosse, Honroe, Tretpealeau 


Hillstone 11 t 2 


8/P 5.63E+06 


3.2 iiles NSN Nea Lomton, CT 


CI: 


Ne« London RI: lent. Providence, Nashington 


Honticello 


B 1.7tf«06 


23 iiles SE of St. Cloud, HN 


NN: 


letton, Isanti, Horrison, Sherburne 


Nine Hile Point 


B 2.04E«0« 


8 iiles NE of Osvego, NY 


NT: 


Lenis, (Osiiego 


Oyster Creek 


B 2.92E«06 


9 tiles S of Tois River, NJ 


HJ: 


Hiddlesei. Honiouth 


Peach Bottot 


B 5.S3E»05 


17.9 iiles S of Lancaster, PA 


PA: 


lerkes, Lancaster, •Lebanon 


Pilgrii 


1 1.27E*06 


25 iiles SE of Boston, NA 


HA: 


Norfolk, Suffolk 


Quad Cities 


B 1.24£»06 


20 iiles NE of Noline, IL 


IL: 


Carroll, Nhiteside lA: Clinton 


VerioDt Tankee 


B 9.23E«04 


5 iiles S of Brattleboro, VI 


NH: 


Cheshire, Sullivan VT: Nindhat 


fort St. Vrain 


B 2.2«E»02 


35 iiles N of Denver, CO 


CO: 


Adots, Boulder, Denver 


Arkansas 1 ( 2 


P 9.68E*04 


6 iiles WW lussellville, AR 


AR: 


Connay, Johnson, Neiiton, Pope, vjn Buren 


6ea»er Valley 


P 3.0«E»03 


Shippingport, PA 


PA: 


Beaver, Butler, Laurence 


Calvert Cliffs 


P 8.24E»04 


45 iiles SE of Nashinqton, DC 


NH: 


Cilvert, Charles, Dorchester, Prince Georges. St. Harys 
Talbot 


Crystal River 


P 1.59E*05 


70 iiles N of Taipa, fl 


FL: 


Alachua, Gilchrist, Narion, Putnat 


Davis Besse 


P 9.41E«03 


21 iiles E of Toledo, OH 


HI: 


Honroe OH: Lucas, OttoKj 


Donald C. Cook 


P 7.34E»04 


11 iiles SSN of St. Joseph, HI 


IN: 


La Porte, St. Joseph HI: Berrien, 'Van Buren 


fort Calhoun 


P 1.01E«04 


19 iiles N of Oiaha, Nt 


lA: 
NB: 


Harrison, Pottatattatie 

•Douglas, 'Sarpy, Saunders, 'Nashington 


H.B. Robinson 


p i.mm 


4.5 iiles NN of Hartsville, SC 


NC: 


Anson SC: Chesterfield, Darlington, Harlboro 


Haddai Neck 


f 1.62Et04 


10 iiles SE of Hiddletovn, CT 


CT: 


Hiddlesei 


Indian Point 1,243 


P 9.l8Et04 


3 iiles SN of Peekskill, Nr 


NY: 


Rockland, Nestchester 


Josepti «. Farley 


P 2.61E«04 


Dothan, AL 


AL: 


Btrbour, Geneva, Henry, Houston GA: Early 


leaaunee 


P 1.05E»04 


27 iiles ESE of Sreen Bay, NI 


NI: 


'Iroan, Door, 'Keaaunee 


tUine rankee 


r I. Him 


3.9 iiles S of Nicassett, M 


HE: 


(ennebec, tnoi, Lincoln, Htldo 


NcGuire 


f O.OOEtOO 


17 iiles N of Charlotte, KC 


NC: 
SC: 


Cabarrus, Cataaaba, Gaston, Hecklenberg, Roaan, Union 
York 


North Anna 


P 3.02E»04 


40 iiles W of Richiond, VA 


VA: 


Caroline, Hanover, Henrico, (ing Nilliat 


Oconee 


P 2.41Et05 


30 iiles N of Sreenville, SC 


SC: 


Greenville, Oconee, Pickens 


Palisades 


P 6.23Et03 


5 iiles S of South Haven, HI 


HI: 


Allegan, Cass, (alatazoo, •Van Buren 


Point leach 


P 5.94E»04 


IS iiles N of Hanitoaoc, NI 


NI: 


•Broan, •Keaaunee, Hanitoaac 


Prairie Island 


P 7.21E*03 


2i iiles SE of ninneapolis, HN 


NN: 

NI: 


Dakota, Goodhue, Hennepin, Ratsey, Scott, Nashington 
Pierce, St. Croii 


RE. Ginna 


P 2.30E»04 


16 iiles NE of Rochester, NT 


NY: 


Honroe, Nayne 


Rancho Seco 


P 2.11Et04 


25 iiles SE of Sacraeento, CA 


CA: 


Aiador, El Dorado, Sacratento 


Salei 1, 2 


P 2.03Et03 


20 iiles S of Hiliinqton, DE 


DE: 


Nea Castle HJ: Cuiterland, Salei 


San Onofre 


P 7.37E«03 


2.5 iiles S of San detente, CA 


CA: 


Orange, Riverside 


Sequoyah 


P 1.20ft04 


Diisr, TN 


IN- 


Hatilton, Heigs, Rhea 


St. Lucie 


P 1.04E«05 


8 iiles S of Ft. Pierce, FL 


FL: 


Indian River, Okeechobee, St. Lucie 


Surry 


P 7.94E»04 


19 tiles NN of He*port Nevs, VA 


VA- 


Charles City, Surry, York 


Three Hile Island 1,2 


P I.OIEW 


10 tiles SE of Harrist-urg, PA 


RA 


SchuykiU, Dauphin, 'Lebanon, Nor thutber land 


Frojan 


P 6.52Et03 


3S tiles NN of Portland, OR 


OR 


Coluibia, Hultanotah NA: Clark, Coaht; 


Turkey Point 


P 9.96Et04 


10 tiles E of Florida City, FL 


FL 


Bronard, Dade 


rankee Ro« 


P 1.29E»03 


20 iiles Ml of Eretnfield, HA 


NA 


franklin NH: 'Cheshire VT- 'Nindhat 


Hon 


P 3 12E«05 


6 tiles H of Naukegan, IL 


IL 


lake NI: (enosha, Racine 


•Counties close to tore 


than one reactor. 







515 



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Council on Economic Priorities 
NEWSLETTER 



Edilar-ia-cM«f : Alice Tcpper Marlin 



Editor: Paula Lippin 



The Council on Economic Pnorilies is a non-profii organization established to disseminate unbiased 
and detailed information on the practices of US. corporations. These practices have a profound im- 
pact on the quality of American life. CEP was established so that the American public could become 
■ware of this impact and work to ensure corporate social responsibility. CEP publishes i-^ Studies 
and/or Reports per year, and a Monthly Newilelter. Memberships and contributions are lax- 
deductible. Indexed in Public Affairs Information Service Bulletin. Excerpts welcomed. Please credit 
the Council on Economic Priorities. 30 Irving Place. New YotL. New York 10003. and send us a 
CODY ISSN 11-193-4066 



For Further Reading 

Quality Of Life In American Neighborhoods: Levels of Affluence, Toxic Waste 

anil Cancer Mortality In Resitlenlial Zip Code Areas. Jay M. Gould. Westview 

Press. 1986 See also CEP Newsletters "Toxic Waste and Cancer: The Link is Getting 

Stronger." Sept. 1984; "Freedom of Information Acl: Breaking the Federal Barrier." 

June 1985; "Toxic Waste tn Chesapeake Bay: Bad for People as Wfell as for Fish.'" Nov 

I98.'i 

Maternal and Child Health Data Book, Children's Defense Fund. Washington. DC. 

1986. 

Radioactive Materials Released From Nuclear Pliwer Plants, 1981, J Tichler and 

C. Benkovitz. Brookhaven National Laboratory. 1984 

Measurement of Low Levels of X-ray Mutagenesis in Relation to Human Disease, 

C. Waldien. L Cortell. MA Sognier. T.T Puck, July. 1986, Proc US Natl Acad- 
emy of Science The data obtained by these investigators, using a new laboratory 
technique involving individual human chromosones implanted in animal cells, show 
thai the effect of low dose radiation exposures is more than 2(X) times greater than had 
previously been assumed on the basis of high dose studies. 

This IS a pan of a rapidly growing body of clinical literature on ionizing radiation 
effects which can be secured from the Health and Energy Institute in Washington. 
DC The detailed annual mortality date for the 175 counties studied here can be 
obtained on a personal compuler diskette Iroiii Public Data Access Inc., 30 Irving 
Place, New York, NY 1(XX)3 (212-529-0890) PDA can assemble diskettes with 
mortality rates for any desired group of states or counties in great detail, and in any 
desired mode, such as Wordstar, Lotus, or DBase 111 



ImiTiedialely responsive to the lethal ef- 
fects of radioactive Iodine included in 
the emissions Table 5 shows that the 
greatest adverse change in the infant and 
fetal mortality rates was registered by 
those counties close to boiling water re- 
actors These counties had emission 
rales of 1.6 curies per capita as against 
0.6 curies per capita for the pressurized 
water reactor counties in the 1975-82 
period 

There is little point at this early stage 
in the investigation to attempt to quanti- 
fy the extent of the adverse impact since 
we do not yet have a satisfactory delinea- 
tion of all the nuclear counties affected 
by both civilian and military reactors. In 
Table 7, the 175 counties adjacent to each 
civilian reactor which we have chosen as 
nuc/ear counties for this Newsletter are 
listed. Almost certainly, there are sev- 
eral hundred more that could be includ- 
ed among those directly or indirectly af- 
fected by emissions from bolh civilian 
and military reactors. It is CEP's hope 
that environmental organizations 
around each reactor will . on reading this 
Newsletter, share with us their knowl- 
edge or even suspicions about those 
counties omitted from our preliminary 
definitions. By adding counties with a 
lesser impact, the average divergence in 
mortality rates from those in nonnu- 
cleariKis will be narrowed_The addi- 
tional deaths, however, will make our 
findings more significant statistically 
and can lead to a more precise quantifi- 
cation of the number of excess deaths lo 
be attributed lo emissions. Until then, 
the estimate of an excess 9000 deaths 
per year derived from this analysis of 
nuclear states can stand as a prelimir 
nary overall estimate. 

It is also clear that CEP's estimates of 
the public health impact of radioactivity 
and other environmental abuses such as 
toxic waste can be made far more pre- 
cise by allowing for differences due lo 
age. sex, and race. Computer tapes 
from the National Center for Health Sta- 
tistics are now in CEP's possession. 
From these tapes, the mortality rates for 
each county, since 1968, for all white 
and nonwhite males and females, by age 
group and for several hundred detailed 
causes of death can be calculated Use of 
this extraordinary database, a tribute to 
the work of statisticians and epidemiolo- 
gists of the National Center, will make it 
possible to pinpoint those groups in our 
population bearing the brum of the 
loss of lives from all environmental 
abuses. ■ 



516 



55b 



(fi^e^</„c 0) 



THE L-^NCET, .\UKCH 7, 1987 



Letters to the Editor 



CANCER NEAR NUCLEAR INSTALLATIONS 

Sir. — Comprchoisivc inlbrmalion on the frequency- of cancer in 
local authorip.' arrd^ in 'jie vicinity of fifrcen nuclear installauons m 
England and \\'aie* has recently been made available to the public' 
Ab you sav in \our n^-te last ucek (Feb 28, p 520) of particular 
interest is the inciiience of leukaemia in 0-2-1-year-olds, since an 
excess inadence r,2s been found near Scllafield in west Cumbria' 
and near Dounreav ' 



STANDAlUMsa;' INCIDENCE .\ND MORTALITT R.\TIOS FOR 
LEUKAEMIA AND ALL CANCERS IS PERSONS AGED 0-24 l^EARS IN 

Locu- Atrnn'K; r^' areas in England .\nd wales tith at 

LE.-<STOS"t-TH:BD OF THfclR POPULATION LIVING WITHIN 10 
MILES OF NUCL£.\R INSTALLATIONS INCLLT)ED INOPCS REPORT 
(LXCtI'I"SEU_\.'-!£La AND IN CONTROL AR£.\S FR0MT.\BLE2 IN- 
OPCS RETORT 







.'and number ol 


cases; 


foryeais: 


— 


|a95a-65t l«*-70 


1971-75 ; 1976-60 


All 


Inci^iHC* 


s 


1 
1 






Leukaemia 


I 








All inslalbuonsi 


"107 //// KH'l?-<. 


112 ili- \ni' 


■/W; 


lll-fi5«; 


Cintrol aras 


w.»j 1 8<)-;';9 


104'JJ«.| 97 


;.W/ 


97 (501/ 


All cancers 




1 






All insullaiKms 


iiy. 5;;.iio3'«;.'/ 


|1I0-.6J9 ;112- 


(.71. 


ioo 12122: 


CuncrpI areu. 


. .-.5 J-)/; :io2.«-'3. 


100 • ■«« [ 103 


fif., 


AW(j/t/v 


i 


1 






Leukaemia 


■' 1 


' 






All insutlations 


<4 W: llW/J-f/ 


111 ;3S:l 96 


W; 


102 lilSi 


Contrpl arou 


■ iij./i(. «)•;;■" 


,114 M/.ilOT 


;;o. 


]I06 isni 
1 99 il42»i 


Alt cincers 


! 


! i 




All instalUions 


tl'i^t. WXJ 


101 Ji^'lOO 


J9J,- 


Control areas 


"S i-'m 97 m 


:iOI i-H 1 97 


m. 


1 9S itUti 


•p<0l>5. ••p'--001 


•;«M-r4:.M-urad<Rcc(lni tAll occpt Sdiandd 





The accc>mp;iir:~^.£ uible r>ho«s for aJl ihe insuilaiions included 
m the OPCS rrrcn. Except ScUafieid, and fur coirt-ipondLng 
conu-ol areas the :cii! iT-ciJencc and mon2lir> ri::os tor leukaemia 
and aJl cancers j: jge C^24 yezrs. The figures include die four time 
penods for u h:ch doa were provided and all the arras sclcaed by 
OPCS for study. O^Tthe whole study period there is a significant 
excess incidence of liLtcaemia and of all cancers in areas in the 
vicinit>' of the installations, but not in the control areas. The 
exclusion of leukaemia from the all -cancer inadence figures for the 
installations leav^ a sr^nificinily increased ratio of 107, based on 
1862 registratiiTis. Considering each ame period separately, 
leukaemia inadence is iigniiiczndy raised only m 1976~S0, and the 
all-cancer inadence in WTl-TS and 197<>-S0. The number of 
oncers near any one installauon is generally small and no 
installation can be sinded out as diffchns signitlcandy from the 
others. In contrast to the incidence daa, none of the mortality ratios 
differs s:5ni:"icantly firom 100. 

The disa-trar.c\' bet^veen lHc incidence and morrality findings is 
importuiu. and the reasons for it will need to be clarified. Some 
posiibilicics include; canoa retpsaraoon nught be more complete or 
cancer survival bencr m the vicinir." of nuclear establishments than 
elsewhere; there might be ditTcrenaat migranon away from nuclear 
instjllauons once a child is diagnosed as having cancer; or the 
increase in cancer inadence might be too recent to be reflected in 
mortabry siadsr.cs. To establish which, if any, of these possible 
explanauons is valid will require detailed investigation. 

The estimated magnitude of the overaU risk is not largfr — an 1 1% 
excess for leukaemia incidence and an 8% excess for all-cancer 
incidence. The^e figures apply lo people living within roughly a 10 
mile (16 km) radius of the installauons. The OPCS data provide 
only crude infonmation on the reladon between nsk and distance 
from the installations. This is because the smallest geographical unit 
studied was the local authont\ area, whose breadth is often more 



than 10 miles, especially in the njral distrias where most nuclear 
installauons are located. For detailed assessment of risk in relation to 
distance from the installations u will be necessar>- to study smaller 
geographical areas, as has been done elsewhere.' ■* 

The data in this report do not go beyond 1980, yet statistics for 
later years should now be available. It is imponant to know whether 
the findings noted here persist. 



Epidcmiotugiol .Mi<ni(t.>rLnB Unit, 

anJ Tropical .\l«licuic, 
Loodw»ClE7MT 



VaLEKIL BER.AL 



I Ctv'V-MozalTan PJ, Vincent T, Fomun D, Ash^ood FL. .\ld«v« M. Cukct 
incidence ami nv»T;i 1 1 r\' in ih^ t'iCTnic>*ornucl«iv LnitalUbori. EngLmd and Vt'jln, 
1950-W> ;5(mJ .\I.-J Popi^ S:Ai no 51 ' London H.M Sucorer> OfTioe. I«R7 

2. Invemgjnon of iheposwbk increased tnodenceofoncermwet Cumbria Repoaot 
(he InJcpcnJcnt AJviion Grvup (chaimun, Sir Dc^gU» Black; Ijxidon. H.M 
Suiioofp. OfTice, 19W 

3 HcuiTun SW, Kemp IW, L'nquan JD, Black R. Ouldhood leuScacmta in noirhcm 
Scodand. Umui 14&6i i: 266. 

4. Roman E, BenI V, Carpcnier L, Wanon A, Banon C, R>der M, Aitgn OL. 
Oiidhood Icukjcmia in (he Wcm Bcrk^hirr and the Basingstoke and North 
Hampshue diMria health juthonne^ in felatjon lo nudnr oabUthmenti m the 
\-iQnity. Bf SUdJ \.\i\ pteu) 



517 



SUMMARY OF ENVIRONMENTAL HEALTH EFFECTS 
FROM NUCLEAR PLANTS 



Leukemia Other In+ant Fetal Congenital Down Wind 
Cancer Mortality Mortality Defects or Coastal 

Windscale, Y N ? Y 

Engl and 

3 coastal Y ? Y 

Scotland 

San Onofre N? N? N? N 

Calif. 

Rocky Flats Y Y Y? Y? Y Y 

Colorado 

Hanford N? Y? Y 

Wash. 

T.M.I. ? Y? Y Y? Y 

Penna. 

All Plants Y Y 

Wi sconsi n 

Yankee Y Y 

Mai ne 

Pilgrim I Y Y 

Mass. 



Prepared 7/30/36 by Sidney Cobb MD , Pro-f Emeritus o-f Community Health 
in Brown University Program in Medicine. The opinions expressed Are his 
not necessarily those o-f the original authors. No claim to completeness is 
made. 

The tentative conclusion is that where there is so much smoke there must 
be some fire. In other words it now seems quite likely that there is some 
hazard to human health from living down wind of some nuclear plants. To 
determine just how much of what conditions and under what circumstances 
is the research task for the future. 



518 



AhreriB R, et al . Letter to the Editor. NEJM 5/22/ 1980; 302: 12U5-6 

HariDi^tJ . Ivijffian E. F'lvder HM, Wstson A. Childhood leulemia in West 

Berkshire., Lancet »1 983; 2: 1243-9. 

ft X « » 1 

BEIR III.' Ihe E-fi'ects o-f E;-cposure to Low Levels o-f lonizinq Radiation: 

1980^ 1980. Wasl-i DC, Nat Acad Press. 

bertell R, Jacobson N, Stoqre M. Environmental influence on survival of 
low birthweiaht infan-t:.s in Wisconsin 1963-75. Internat Persp Pub Health 
1984; l! 12- 24. 

Bertell R. Handbook -for Estimating Health E-f-fects from Exposure to 
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» » * i 

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»»»» 

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*«»» -• 

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»♦»« 

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♦»«■«■ 

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**** 

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**** 

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**** 

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**** 

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**** 

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♦•»» 

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»»»» 

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«««« 

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«■•»* 

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»»»» 

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»»»» 

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I **** 

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**** 

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**** 

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♦»♦« 

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»«*♦ 

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»*■»» 

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_.. •♦•* 
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1/ ^*-j^—-i ■ 

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♦ *»♦ 

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♦♦»» 

Woolard RF , Voung ER Health Dangers of the Nuclear Fuel Chain and 

Low-Level Ionising Radiation May 1979. 



524 



statement of Coimissioner James K. Asselstine 
U.S. Nuclear Regulatory Conmission 

before the 

Subcommittee on Energy Conservation and Power 

Committee on Energy and Conmerce 

May 22, 1986 



Mr. Chairman, I disagree in many respects with the Conmission' s testimony 
on the impact of the Chernobyl accident. Now that the Chernobyl accident 
has turned the spotlight onto the safety of the U.S. nuclear power 
reactors, the Conmission would have the Congress and the public believe 
that the U.S. plants may be five times safer than estimated just a few 
months ago, that the U.S. plants are far safer than the Commission's 
provisional safety goals, that the U.S. plants are much safer than believed 
when the Conmission deemed the severe accident risks to be acceptable last 
year, and that the consequences of a core meltdown in the U.S. are "very 
different" than the consequences of a core meltdown in the Soviet Union. 
Indeed, the Commission now seems to believe that the TMI inspired backfits, 
which many argued before Chernobyl to have questionable if not negative 
impacts on safety, have turned out to be very positive contributors to 
safety. Before Chernobyl, those "undisciplined" TMI backfits served as 
part of the basis for the promulgation of the Conmission's backfit 
rule, which erects a substantial barrier against efforts to improve safety. 
After Chernobyl, the Commission and the nuclear industry find that those 
TMI backfits have provided substantial improvements in safety. Finally, 
according to the Commission, apart from finding that the light water 
reactors in the U.S. cannot have large graphite fires, it is premature to 



525 



draw conclusions regarding the ramifications of the Chernobyl accident for 
our nuclear power program. 

Mr. Chairman, by focusing on the design differences between the Soviet 
plants and U.S. plants, the Commission misses the broader lessons of the 
Chernobyl accident for nuclear safety in the United States. Those broader 
lessons have to doj«1th the acceptability of core meltdown accidents and 
the adequacy of our current efforts to prevent such accidents and to 
minimize their consequences should one occur. I want to start with what I 
think are three Inesc apable conclusions regarding the risk of core meltdown 
accidents In the United States. 

n y First, unless further steps are taken to reduce substantially the likeli- 
hood of a core meltdown accident, we can expect to see such an accident at 
a U.S. plant within the next 20 years. This conclusion is supported by the 
probabilistic risk assessments done for U.S. plants to date, by the 
substantial uncertainties in those assessments. Including their limited 
ability to account for human performance and external accident Initiators, 
and by recent operating experience with the plants which shows that at 
least some PRA assumptions are overly optimistic. As the Comnission's 
chief safety officer noted recently, serious operating events illustrate 
that In the real world, system and component reliabilities can degrade 
below those we and the Industry routinely assume in estimating core melt 
frequencies. 



526 

- 3 - 

Second, as Is apparently the case with the Soviet reactors, our reactors 
were not designed for large-scale core meltdown accidents. Because such 
accidents were assumed to be so unlikely as to be incredible, they were 
judged to be outside of the design basis for the plants. One consequence 
of this assumption is that U.S. reactor containments were designed to 
withstand the rupture of a large steam pipe but were not designed to 
withstand large-scale core meltdowns. 

i Third, although we believe that all of our reactors have some capability to 
withstand severe core meltdown accidents, the extent to which they can 
withstand such accidents depends upon the sequence of events during the 
accident, the individual plant designs and the manner in which each plant 
is operated and maintained. While we hope that their occurrence is 
unlikely, there are accident sequences for U.S. plants that can lead to 
rupture or bypassing of the containment in U.S. reactors which would result 
In the off-site release of fission products comparable to or worse than the 
releases estimated by the NRC staff to have taken place during the 
Chernobyl accident. That is why the Conmisslon told the Congress recently 
that It could not rule out a commercial nuclear power plant accident in the 
United States resulting In tens of billions of dollars in property losses 
and injuries to the public. The bottom line is that, given the present 
level of safety being achieved by the operating nuclear power plants in 
this country, we can expect to see a core meltdown accident within the next 
20 years and it is possible that such an accident could result in off-site 
releases of radiation which are as large as, or larger than, the releases 
estimated to have occurred at Chernobyl. 



V. 



527 



4 - 



My point Is that large power reactors. In this country and abroad, are not 
Inherently safe. Each design has Us own core meltdown vulnerabilities. 
If nothing else Chernobyl should remind all of us that core meltdown 
accidents can happen and, even assum ing evacuation Is successful, that the 
resulting releases can leave largetracts of land and buildings highly 
contaminated. 

To me, the lessons of Chernobyl are simple and straightforward. Given the 
uncertainties in containment and plant performance, the occurrence of a 
severe core meltdown accident over the next 20 years is unacceptable. That 
was the judgment of the President's Commission on the Three Mile Island 
Accident six years ago, and it is no less true today. We should return to 
the safety philosophy espoused by the Kemeny Comnlssion at that time — to 
pursue all practical measures both to prevent core meltdown accidents^rom 
occurring and to minimize their consequences should one occur. This safety 
philosophy is fundamentally at odds with the Commission's decision in the 
Indian Point Special Proceeding, with the Severe Accident Policy Statement, 
with the Commission's backfit rule and with the Conmisslon's provisional 
safety goal. It is also at odds »(1th the passion for deregulation that has 
been sweeping the nuclear Industry and the Conrilssion over the past two 
years. 



Many other countries have and are _tak1^ng U.S. -developed technology and 
minimum safety standards, and buildin g on them to have better nuclear 
plants with greater defense-In-depth than that being achieved in this 
country. These other countries have better designed plants that are 



528 



5 - 



operated and maintained better than the U.S. plants and that are safer than \ 
the U.S. plants. They have achieved a far better state of affairs with 
respect to reliability and safety of their plants than this country has. 
And, they have accomplished this in a disciplined manner at reasonable 
costs. While we are looking at foreign safety experience In the aftermath 
of the Chernobyl accident, we should consider following their example. 
Thank you. 



J 



529 




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531 

The Chairman. Our final panel this evening is comprised of the 
people who make the decisions, Nuclear Regulatory Commission 
and the Federal Emergency Management Agency. We heard a 
great many serious concerns, voices, this evening about the way in 
which the NRC and FEMA are regulating the Pilgrim plant, are 
planning for emergency preparedness. Here this evening to respond 
to these questions is Dr. Thomas Murley, director of the NEC's 
Office of Nuclear Reactor Regulation. Along with Dr. Murley is Mr. 
William Russell, NRC's regional administrator. Also on the panel 
are the representatives from FEMA, Mr. Richard Krimm, the as- 
sistant associate director of FEMA and Mr. Jack Dolan from 
FEMA Region Number I. And I'm anxious to hear from you, gen- 
tlemen, in response. 

First of all, we'll hear from Mr. Krimm 

STATEMENTS OF RICHARD KRIMM, ASSISTANT ASSOCIATE DI- 
RECTOR OF FEMA; DR. THOMAS MURLEY, DIRECTOR OF THE 
NCR'S OFFICE OF NUCLEAR REACTOR REGULATIONS; WILLIAM 
RUSSELL, NCR'S REGIONAL ADMINISTRATOR, REGION I; AND 
JACK DOLAND, FEMA REGION I 

Mr. Krimm. Thank you very much. 

The Chairman. They have been sworn in. 

Mr. Krimm. My name is Richard Krimm. I'm the assistant asso- 
ciate director of the Federal Emergency Management Agency re- 
sponsible for the development and management of FEMA's pro- 
gram related to technological and natural hazards. These programs 
include radiological emergency planning [REP] around nuclear 
powerplants, as well as planning for hazardous materials incidents, 
earthquakes, dam safety and hurricanes. Accompanying me is Mr. 
Jack Dolan, FEMA Region I, Boston, and Mr. George Watson, from 
our Office of General Counsel. 

The primary concern of FEMA's REP program is the health and 
safety of the public around nuclear power plants. FEMA works to 
achieve this goal through an evaluation of plans and preparedness 
under the FEMA regulation. The evaluation process includes par- 
ticipation by regional assistance committees, [RAC] chaired by 
FEMA, and includes nine other Federal agencies. 

The RAC reviews State and local plans against published crite- 
ria, and agency representatives give advice on their particular area 
of expertise. The published criteria were developed jointly by the 
FEMA and the NRC with full public participation and contains all 
the established Federal criteria for developing, reviewing and eval- 
uating radiological emergency, planning and preparedness for com- 
mercial nuclear powerplants. 

Ultimately, the plans are reviewed and approved at FEMA head- 
quarters. Following approval, FEMA notifies the NRC and the Gov- 
ernor and publishes a notice in the Federal Register. This is done 
only if a determination is made following appropriate plan exer- 
cises that there is reasonable assurance that the public health and 
safety can be protected in the event of a radiological emergency at 
the plants. 

Let me just briefly discuss Pilgrim. In a series of meetings with 
the Commonwealth and the local communities in the spring of 



532 

1986, FEMA identified problems with the Commonwealth's emer- 
gency response plan. Based on issues raised at these meetings and 
information received subsequently, FEMA decided to conduct a 
review of the emergency response plan and preparedness for the 
Pilgrim nuclear power station, and so informed the Commonwealth 
in a letter to the Massachusetts Civil Defense Agency on Septem- 
ber 5, 1986. 

On December 22, 1986, the Secretary of Public Safety, Charles 
Barry, forwarded to FEMA a copy of the report to the Governor on 
emergency preparedness for an accident at the Pilgrim Power Sta- 
tion. This report stated that the Massachusetts plan and its pre- 
paredness are inadequate to protect the health and safety of the 
public in the event of an accident at the Pilgrim nuclear power sta- 
tion. In the course of its self-initiated review, FEMA treated this 
report as the authoritative and current position of Commonwealth. 

On August 6, 1987, FEMA transmitted to the Commonwealth of 
Massachusetts and the NRC its report entitled, "Self-Initiated 
Review and Interim Finding for the Pilgrim Nuclear Power Sta- 
tion." The report was provided to the Commonwealth and NRC 
pursuant to the regulation and identified six areas of major con- 
cern. 

These are lack of reception centers for people evacuating to the 
north; lack of evacuation plans for public and private schools and 
day-care centers; and lack of identifiable public shelters for the 
beach population; inadequate planning for the evacuation of the 
special needs population; inadequate planning for evacuation of the 
transport dependent population, and overall lack of progress in 
planning in emergency preparedness. 

Based on the Self-Initiated Review and Interim Finding, FEMA 
concluded that Massachusetts offsite radiological emergency plan- 
ning and preparedness was inadequate to protect the public health 
and safety in the event of an accident at Pilgrim. The current 
status of this when we translated the Self-Initiated Review to Mas- 
sachusetts, we suggested that they work with us to develop a plan 
and schedule to correct the inadequacies in their plan. The Com- 
monwealth has not yet developed such a work plan as scheduled. 

However, since the issuance of the new interim finding and the 
publication of FEMA's Self-Initiated Review and Interim Finding 
on Pilgrim, the Commonwealth of Massachusetts has taken action 
to address some outstanding issues. 

FEMA looks forward to working with the Commonwealth and af- 
fected communities in order to achieve our common goal of protect- 
ing the public health and safety. 

We are prepared to respond to your questions, Senator Kennedy. 

[The prepared statement of Mr. Krimm follows:] 



533 



STATEMENT BY RICHARD W- KRIMM 
ASSISTANT ASSXIATE DIRECTOR 
OFFICE OF NATURAL AND TECHNOLOGICAL HAZARDS PROGRAMS 
STATE AND LXAL PROGRAMS AND SUPPORT DIRECTORATE 
FEDERAL EMERGENCY MANAGEMENT AGENCY 
BEFORE THE 
COMMITTEE ON LABOR AND HUMWJ RESOURCES 
U.S. SENATE 
IN PLYMOUTH, MASSACHUSETTS 

JANUARY 1, 1988 



534 



My name is Richard W. Krimm. I am Assistant Associate Director of 
THE Federal [lmergency Management Agency (FEMA) responsible for the 

DEVELOPMENT AND MANAGEMENT OF FEMA's PROGRAMS RELATED TO TECHNOLOGICAL 
AND NATURAL HAZARDS- ThESE PROGRAMS INCLUDE RADIOLOGICAL EMERGENCY 
PLANNING AROUND NUCLEAR POWER PLANTS, AS WELL AS PLANNING FOR HAZARDOUS 
MATERIALS INCIDENTS, EARTHQUAKES, DAM SAFETY AND HURRICANES- AlSO, AS 

office director, i chair the federal radiological preparedness coordinating 
Committee (FRPCC) which includes officials from the Departments of Energy, . 
Commerce, Health and Human Services, Transportation, Agriculture, Interior, 
Defense, the Environmental Protection Agency and the Nuclear Regulatory 
Commission- In addition, I co-chair with the Nuclear Regulatory Commission 
(NKC) monthly meetings of the FEMA/NRC Steering Committee- These two 
committees, at the National level, deal with policy matters related to 
offsite planming and preparedness at commercial nuclear power plants 
across the country- 

i am pleased to appear before you to represent the federal emergency 
Management Agency and to discuss the Radiological Emergency Preparedness 
(rep) program, as it relates to offsite emergency planning in the plume 
exposure emergency planning zone for the pilgrim nuclear power station- 

Accompanying me is Mr- Jack Dolan, FEMA Region I, Boston and Mr- George 
Watson from our Office of General Counsel- 

Before discussing Pilgrim specifically, I would like to outline the context 

OF PROGRAM PROCEDURES AND PHILOSOPHY IN WHICH THE PiLGRIM SITUATION HAS 

unfolded- The primary concern of FEMA's REP program is the health and safety 



1 - 



535 



OF THE PUBLIC AROUND NUCLEAR POWER PLANTS- FEMA WORKS TO ACHIEVE THIS GOAL 
THROUGH AN EVALUATION OF PLANS AND PREPAREDNESS UNDER THE FEMA REGULATION 

44 CFR 350- This FEMA process, governed by the regulation, primarily involves 

A FORMAL submission BY THE GOVERNOR. OR HIS/HER DESIGNEE. OF THE STATE AND 
LOCAL PLANS FOR THE EMERGENCY PLANNING ZONE (EPZ) AROUND A SPECIFIC NUCLEAR 
POWER PLANT. ThE EVALUATION PROCESS INCLUDES PARTICIPATION BY A REGIONAL 

Assistance Committee (RAC). chaired by FEMA. which includes, at the Regional 

LEVEL. THE SAME AGENCIES I MENTIONED AS BELONGING TO THE FRPCC 

The RAC reviews the State and local plan, against published criteria (NUREG-0654/ 
FBIA-REP-l. Rev. 1). and agency representatives give advice on their particular 
areas of expertise. The published criteria were developed jointly by FEMA and 

NRC WITH FULL public PARTICIPATION AND CONTAINS ALL THE ESTABLISHED FEDERAL 
CRITERIA FOR DEVELOPING. REVIEWING AND EVALUATING RADIOLOGICAL EMERGENCY 
PLANNING AND PREPAREDNESS FOR A COMMERCIAL NUCLEAR POWER PLANT EMERGENCY. 
The PUBLISHED CRITERIA CONTAIN 16 MAJOR PLANNING STANDARDS. WHICH ARE FURTHER 
BROKEN DOWN INTO 196 EVALUATION CRITERIA ADDRESSING SUCH ELEMENTS AS EMERGENCY 
COMMUNICATIONS. PUBLIC WARNING. AND PUBLIC EDUCATION AND INFORMATION. 

The APPROPRIATE FEMA Regional Office coordinates the planning review and 

ASSURES that AN EXERCISE IS CONDUCTED TO ADEQUATELY TEST THE PLANS. ThE 

Regional Uffice or State also conducts a public meeting to inform interested 

PARTIES of the CONTENT OF THE PLANS AND WHAT WOULD BE EXPECTED OF THE PUBLIC 
IN THE EVENT OF AN EMERGENCY AT THE PLANT- FEMA. THROUGH THE PUBLIC MEETING 
FORUM ENSURES THAT THE PUBLIC INPUT IS CONSIDERED AND INCORPORATED INTO THE 
DESIGN OF THE PLANS. WHERE APPROPRIATE. 



536 



In addition, FEMA also provides technical assistance to State and local 
governments to enhance the overall planning and preparedness effort. as an 
example, FEMA has frequently provided technical assistance TO THE Commonwealth 

IN THE development OF PLANS PURSUANT TO OUR REGULATIONS- ANOTHER EXAMPLE OF 

this is our training program, which includes courses in radiological emergency 
response planning and accident assessment at the fbia national emergency 
Training Center in Emmitsburg, ^Vvryland, and a course to train Radiological 
Emergency Response Teams at the Nevada Nuclear Test Site. These courses are 

PRIMARILY for StATE AND LOCAL OFFICIALS- 

Ultimately, the plans are reviewed and approved at FEMA Headquarters- Following 
APPROVAL, FEMA notifies the NRG and the Governor and publishes a notice in the 
Federal Register- This is done only if a determination is made, following 
appropriate plan exercises, that there is reasonable assurance that the public 
health and safety can be protected in the event of a radiological emergency 
at the plant. However, the process does not end with the initial approval. 
The State and the affected local governments must continue to keep plans 
updated and they must also participate in periodic exercises with the utility 
as a condition of continued FEMA approval. 

FEMA AND NRC HAVE also signed a Memorandum of Understanding (MOU), most 
recently revised in April, 1985- This MOU calls for FEMA to supply NRC with 
advice on offsite preparedness issues. Typically, under the MOU, FEMA provides 
"interim* offsite safety findings that are used in licensing decisions made 
BY THE NRC. These "interim" findings are a snapshot in time of the preparedness 



- 3 



537 



POSTURE AT A GIVEN SITE- It IS IMPORTANT TO NOTE THAT FINDINGS MADE UNDER 
OUR REGULATION (44 CFR 350) OR INTERIM FINDINGS UNDER THE MOD ARE MADE ON 
THE SAME BASIS^ THAT IS, UNDER THE PUBLISHED CRITERIA- 

PlLbKIM 

In a SERIES OF MEETINGS WITH THE COMMONWEALTH AND LOCAL COMMUNITIES IN THE SPRING 

of 1986, fel^a identified problems with the commonwealth's emergency response plans- 
Based on issues raised at these meetings, and information received subsequently, 
FEMA decided to conduct a review of the emergency response plans and preparedness 
for the Pilgrim IJuclear Power Station and so informed the Commonwealth in a 
letter to the Massachusetts Civil Defense Agency (MCUA) on September 5, 1986. 

On December 22, 1986, the Secretary of Public Safety, Charles Barry, fowarded 
TO FEMA A COPY OF the "Report to the Governor on Emergency Preparedness for 
AN Accident at the Pilgrim Nuclear Power Station" (hereinafter called the 
Barry Report). This report stated that the Massachusetts plan and its 
preparedness are inadequate to protect the health and safety of the public in 

THE event of an ACCIDENT AT THE PiLGRIM NuCLEAR PoWER STATION- FEMA WAS 

subsequently informed that the governor and the director of the massachusetts 
Civil Defense Agency had endorsed the Barry Report- In the course of its 
self- initiated review, fema treated this report as the authoritative and 

current POSITION OF THE COMMONWEALTH- 

On August 6, 1987, FEMA transmitted to the Commonwealth of Massachusetts and 
THE NRC its report entitled "Self-Initiated Review and Interim Finding 
for the Pilgrim Nuclear Power Station"- The report was provided to the 
Commonwealth and NRC pursuant to the regulation and identified six (6) areas 

OF MAJOR concern; 



538 



- Lack of a reception center for people evacuating to the north. 

- Lack of evacuation plans for public and private schools and daycare centers- 

- Lack of identifiable public shelters for the beach population- 

- Inadequate planning for the evacuation of the special needs population- 

- Inadequate planning for evacuation of the transport dependent population- 

- Overall lack of progress in planning and apparent diminution in emergency 
preparedness- 
Based on the Self-Initiated Review and Interim Finding, FEMA concluded that 
Massachusetts offsite radiological emergency planning and preparedness was 
inadequate to protect the public health and safety in the event of an accident 
AT Pilgrim. 

Shortly thereafter, NRC informed the Boston Edison Company of FEMA's finding- 
They encouraged the utility to address the underlying issues in cooperation 
WITH THE Commonwealth and stated that the status of all issues upon which 
the finding was based would be taken into consideration in decisions about 
the restart of the plant- NRC's prompt notification to the licensee about 
the offsite problems at the site is consistent with the FEMA/NKC policy of 
cooperative effort towards addressing issues of this serious nature- 

Current Status 

^EN we transmitted THE SELF" INITIATED REVIEW TO MASSACHUSETTS WE SUGGESTED 
THAT THEY WORK WITH US TO DEVELOP A WORK PLAN AND SCHEDULE TO CORRECT THE 
INADEQUACIES IN THEIR PLAN- ThE COMMONWEALTH HAS NOT YET DEVELOPED SUCH A 
WORK PLAN OR SCHEDULE; HOWEVER, SINCE THE ISSUANCE OF THE NEW INTERIM FINDING 



5 - 



539 



AND THE PUBLICATION OF THE FEMA SeLF'In ITIATED REVIEW AND INTERIM FINDING 

ON Pilgrim, the Commonwealth of Massachusetts has taken actions to address 
outstanding issues: 

° On December 17, 1987, in a letter from Governor Dukakis to our Regional 
Director, Mr- Henry Vickers, the Commonwealth indicated that progress is 
being made in several areas- for example, they indicated that draft revisions 

TO THE LOCAL PLANS EXIST IN PART FOR EACH OF THE FIVE EPZ COMMUNITIES- In 
SOME CASES THE DRAFT REVISIONS WERE INDICATED AS BEING UP TO SSI COMPLETE- 
ThEY FURTHER STATED THAT WHEN OFFICIALS OF ALL OF THE COMMUNITIES AND 
STAFF OF THE MASSACHUSETTS CiVIL DEFENSE AgENCY/OfF ICE OF EMERGENCY 

Preparedness indicate that the initial drafts are completed, the drafts 

WILL BE submitted TO FEMA FOR INFORMAL TECHNICAL REVIEW- 

° The Massachusetts Bureau of Radiation Protection, which is part of the 
Commonwealth of Massachusetts Department of Public Health, has submitted 
TO FEMA A draft of their ingestion pathway plan which the RAC is reviewing 
at this time and plans to complete by the end of January at which time 

THE RAC's comments WILL BE FORWARDED TO THE COMMONWEALTH - 

FEMA LOOKS FORWARD TO WORKING WITH THE COMMONWEALTH AND AFFECTED COMMUNITIES 
IN ORDER TO ACHIEVE OUR COMMON GOAL OF PROTECTING THE PUBLIC HEALTH AND 
SAFETY- We STAND READY TO PROVIDE TECHNICAL ASSISTANCE TO THE AFFECTED PARTIES 
IN THE RESOLUTION OF OFFSITE ISSUES ASSOCIATED WITH THIS SITE- 

We are PREPARED TO RESPOND TO YOUR QUESTIONS- 



540 

The Chairman. We'll hear from both the representatives of 
FEMA. 

Mr. DoLAN. I don't have a statement Senator. 

The Chairman. I want to say first of all, how much we appreci- 
ate your attendance here, Mr. Krimm. I understand that there 
have been occasions when FEMA has not been so willing to attend 
meetings. I also want to say that I regret FEMA's decision concern- 
ing the participation of Mr. Ed Thomas. It is unfortunate that the 
agency doesn't feel that this hearing was of sufficient importance 
to warrant Mr. Thomas' presence. 

I've had the opportunity to review the emergency preparedness 
plan which was in place when FEMA published its interim finding, 
that the plan offered reasonable assurance that the public could be 
protected in the event of radiological emergency. I'd like for a 
moment to present some excerpts from the FEMA's subsequent 
self-initiated review of that plan. 

I quote: 

Existing local plans do not include a list of the resources the town plan used in 
assisting mobility impaired people during evacuation. FEMA could no longer state 
with confidence that the beach population can be protected; FEMA can no longer 
state with confidence that a reasonable assurance exists that the health and safety 
to transport the dependent population can be protected in the event of an accident. 

These are just a few of the serious deficiencies quoted in FEMA's 
own assessment. 

I would like to know, Mr. Krimm, how a plan so obviously defi- 
cient could possibly have received interim approval by FEMA? 

Mr. Krimm. In early 1980, when we did give approval I think 
that, number one, we were new in the game, as was the Common- 
wealth of Massachusetts. We were really just starting out. We have 
gotten more staff and we have become more expertise in reviewing 
plans and making our findings to the NRC. 

The Chairman. Well, it would seem you wouldn't need a lot of 
experience in developing an evacuation plan if the plan didn't in- 
clude a list of the resources to be used in assisting mobility im- 
paired people; and it says that you can no longer state with confi- 
dence that the beach population can be protected; and you can no 
longer state with confidence that reasonable assurance exists that 
the health and safety of the dependent population can be protected; 
those are pretty basic and fundamental questions, I would think. I 
mean, you don't have to be terribly new in the game to understand 
if you can't find ways of evacuating people who are sick or infirm, 
it would seem to me that that would pretty well jump out at you. I 
mean, if you can't evacuate the people along the beach popula- 
tion — those things would be pretty self-evident, it would seem to 
me in terms of raising serious questions about the effectiveness and 
the efficiency of such a plan. 

Mr. Krimm. I believe that when Mr. Thomas and his staff re- 
viewed the plans that they did assume that some of those things 
were in order because they had been working with the Common- 
wealth. 

I don't know, Mr. Dolan, if you would like to make any further 
comments at this time. 

Mr. Dolan. I think at the time when I was there, we became 
much more sophisticated with what we did. And when we started 



541 

with this work in 1982, it was in its infancy, and the other thing 
that is an important factor is the fact that the population changed 
dramatically in this area, and that had a profound effect on both 
the identification of mobility impaired people, and, additionally, 
the protection of the beach population. 

The Chairman. Does the fact that FEMA missed the important 
problems the first time around indicate that FEMA needs addition- 
al staffing to evaluate emergency preparedness plan? 

Mr. Krimm. Senator Kennedy, fortunately, in the past few years 
that we have received additional staff from the Congress, and the 
Congress in fiscal year 1988 appropriation budget, gave us 10 addi- 
tional positions. Some of these additional positions will be put into 
the Boston regional office. 

The Chairman. Has there been an increase for Massachusetts, 
for example? 

Mr. Krimm. Yes, sir. We are increasing the staff 

The Chairman. You are increasing. Has there been an increase 
as of today? 

Mr. Krimm. As of today, there are just six people allocated to us. 

The Chairman. How many were there two years ago? 

Mr. Krimm. I'm not sure how many. 

Mr. Dolan. Eight. [Laughter.] 

The Chairman. So there were eight people two years ago. That's 
some arithmetic. Well 

Mr. Krimm. It was the case, Senator Kennedy, people sometime 
leave the agency. 

The Chairman. Well, I know that. But I mean, that's a tough 
way to try to explain to somebody about problems in evacuation 
plans that you missed. I happen to be very sympathetic to agencies. 
I wish they would come out and say, "we can't get the job done 
unless you give us the personnel, and don't expect us to do it." You 
know, I like to hear that. We're realistic and understand you have 
to live with the rest of it, but there is no reason for professional 
people to take that kind of abuse. If you haven't got the people, 
then you can't do the job, and then you are doing them an enor- 
mous disservice with the responsibility that you have. I think it's 
unfair to you, and I think it's unfair in terms of trying to deal with 
an issue that is so vital with respect to people's lives. I don't want 
to belabor the point, but say we are talking about some matters af- 
fecting very, very considerable public health and safety issues, and 
the American people are certainly entitled to understanding these 
things. 

Let me quote from the FEMA's Self-Initiated Review during the 
June 30, 1986, public meeting in the town of Plymouth, "the citizen 
whose children attended private schools inquired about the plans 
for their evacuation. FEMA promptly researched that and discov- 
ered for the first time that private schools were not included in the 
local plans." 

Is that, Mr. Krimm, how FEMA usually assesses a plan— by 
waiting for the local citizens to ask you whether their children are 
protected? Why is it that people have to ask? Why is it that you 
missed something that would probably be as basically fundamental 
as that? You did miss that. Is the rest of the plan flawed? 



542 

Mr. Krimm. As a rule, Senator Kennedy, we do try to be very 
thorough, but one of the purposes of having public meetings is to 
allow the local citizens to bring to our attention things that my 
have been overlooked, and that is a very important part, trying to 
get public input into the 

The Chairman. Well, if you believe that's the case, why doesn't 
the NRC believe that's the case when they hear from local citizens? 
Well, I'll have a chance to ask them. 

Focusing on the issue of the Memorandum of Understanding be- 
tween FEMA and the NRC, it is my understanding from the NRC 
that FEMA serves as the offsite expert on emergency preparedness 
plans, is that so? 

Mr. Krimm. Yes 

The Chairman. Yet the NRC also says that FEMA's advice is 
nonbinding; that the NRC can accept or reject FEMA's findings; is 
that so? 

Mr. Krimm. Yes. 

The Chairman. Does it not appear contradictory to you that the 
NRC claims FEMA to have the expertise on emergency prepared- 
ness, but reserves for itself the right to overrule your determina- 
tion? 

Mr. Krimm. Well, the NRC has the authority in the licensing in 
making the determination 

The Chairman. I understand 

Mr. Krimm [continuing]. Excuse me. We do act as a consultant to 
them. We provide the information to the NRC, and, of course, it is 
their determination what they do with our information. 

The Chairman. Well, I know what the law says, but, I mean, the 
logic, the common sense; you are the expert, you make recommen- 
dations they can ignore. What sense of confidence do you think 
people ought to have in terms of that process and procedure? I 
mean, it's 

Mr. Krimm. Excuse me. I would say in many cases, Senator Ken- 
nedy, that the NRC does take our advice and does consider our 
findings. For example, in 1983, we made a negative finding at the 
Indian Point power plant in New York State, and the NRC did 
take action to issue, what is known as a 120-day clock, whereby 
they advise the utility that they would close the plant. 

The Chairman. Did they close it? 

Mr. Krimm. No. Because the issues were cleared up. Governor 
Cuomo developed an emergency plan for Rockland County which 
was a nonparticipating county at that time 

The Chairman. Well, wasn't a result of it that the NRC actually 
overruled FEMA and allowed the Indian Point to restart? 

Mr. Krimm. No, sir. The emergency plans were developed and 
the deficiencies were cleared up. 

The Chairman. And FEMA approved the final plans? 

Mr. Krimm. We approved the final plans. The major deficiency 
at Indian Point at that time was the failure of Rockland County to 
participate and the State of New York cleared that up. And we 
also worked with Westchester County on the bus issue, and with 
some of the other counties with some of their problems 

The Chairman. At the present time, the federal regulations re- 
quire that an area encompassing a 10-mile radius of a nuclear 



543 

power plant have an evacuation plan. Did you know Cape Cod lies 
just outside the 10-mile radius. It is my understanding that in the 
event of a full-scale evacuation Sagamore Bridge would be closed to 
off Cape traffic, and all residents seeking to leave the Cape would 
be rerouted over Bourne Bridge. 

Now, I don't know if you ever had the pleasure [laughter] of 
trying to drive through the Cape at the end of a sunny, lovely 
summer weekend, but I can assure you, as a resident, that the ex- 
perience is not a pleasant one. It is not uncommon to experience 
hours of traffic delays when both bridges are open for use, and I 
cannot imagine the nightmare that would ensue if Cape Cod resi- 
dents were asked to use only one of the bridges for emergency evac- 
uation. 

I would ask you, do you really feel that the residents are ade- 
quately protected? Let me remind you that in the case of the Cher- 
nobyl accident, significantly more than a 10-mile radius was evacu- 
ated. In the case of Three Mile Island accident, over 100,000 people 
left the area; in spite of the instructions that told them to stay. 

Mr. Krimm. I'm very sorry that I'm not familiar with that par- 
ticular area. I would like to ask Mr. Dolan to respond to that. 

Mr. Dolan. Senator, in 1984, at the request of the NRC and as a 
result of a petition, we did an extensive study of the traffic man- 
agement in the area of^from the plant to the other side of the 
bridge on the Cape Cod Canal. And the state participated in depth 
in that study. 

Our experts told us that the Cape could be evacuated using the 
procedures set forth by the Massachusetts State Police and the 
Massachusetts Department of Public Works. And currently, the 
Commonwealth of Massachusetts has told us that they are again 
taking a look at the situation with regard to that and they are con- 
templating the expansion of the emergency planning zones of the 
Pilgrim power plant to include the towns of Bourne, Wareham, and 
the third escapes me, the towns in that area, and that's where it 
stands right now. 

The Chairman. Have you been down there recently? 

Mr. Dolan. Oh, yes, sir. All my life. 

The Chairman. Well, you can take some judicial notice, as they 
say, of what those weekends are like and what just ordinary traffic 
is like. 

Mr. Dolan. Well, Senator, I believe it can be evacuated as long 
as it can be managed properly. [Laughter.] 

The Chairman. I don't know what's not managed properly on 
just ordinary weekends, just ordinary traffic; and this is one of the 
growth areas of the country, not only of our state, but of the coun- 
try. And even if you left down that whole railroad bridge, and you 
had people scampering across there. [Laughter.] 

It really defies the common understanding. 

As I understand it, Mr. Krimm, you are from the Washington 
headquarters? 

Mr. Krimm. Yes, sir. 

The Chairman. Do you have any great knowledge of these evacu- 
ation plans? 

Mr. Krimm. Not specifically the area that you mention. I am fa- 
miliar with certain evacuation plans throughout the country. 



544 

The Chairman. The area that I was just talking about, Cape Cod; 
what about this area here? 

Mr. Krimm. No, sir. I'm not. 

The Chairman. Well, it would seem to me that someone of your 
responsibility would have some information about one of the key 
elements in terms of an evacuation plan. You've got major respon- 
sibilities, as I understand, in making some judgments on this. And 
it kind of appalls me that — I mean, I don't expect you to have the full 
information, perhaps the detailed information that the people in the 
locale have, but I would certainly hope that, given the kinds of 
problems that have affected this particular plant and the signifi- 
cance of the evacuation issue that s been very much a part of the 
concern of everyone in this state, and I would think people around 
the country, that you would have given it the kind of attention 
that apparently you have given to some of the others. 

In view of the fact that FEMA is unable to supercede the NRC's 
decision on emergency preparedness, would FEMA support a con- 
gressional requirement to give FEMA the authority to override the 
NRC on issues of emergency preparedness? 

Mr. Krimm. I listened very carefully when the Lt. Governor 
brought that up. If I may submit something for the record, I would 
like to think about it a little before. I would like to try to develop 
the cons and pros for it, I would submit something for the record. 

The Chairman. When you do, we'll make that available to the 
citizens up here. But what I'm really interested in is FEMA's sup- 
port for its having the final decision over whether a plant stays 
open — if the public cannot be reasonably assured of evacuation pro- 
tection; that would be the question I'm interested in your response 
to. 

[Response of Mr. Krimm to Senator Kennedy's question follows:] 

Response to Previous Question 

Answer. In response to your questions if the FEMA would support legislative 
action to give the FEMA the authority to override the Nuclear Regulatory Commis- 
sion (NRC) on issues of offsite emergency preparedness, the FEMA does not recom- 
mend that it be given such authority, at this time, for the following reasons: 

1. On the whole, the NRC has used and reflected FEMA's offsite findings and de- 
terminations in all of its licensing decisions. This woudl indicate that the present 
arrangements are satisfactory. 

2. A change could bifurcate the current integrated licensing process resulting in 
two separate licensing processes, onsite and offsite. 

3. It is estimated that the FEMA would require an additional staff of 50 to 75 FTE 
and an increased annual budget of $7 to $8 million dollars. The additional resources 
are required for judicial reviews, hearings, public meetings and administrative re- 
quirements needed for a regulatory activity. 

The Chairman. One final question, you mentioned in your testi- 
mony the report by Secretary Barry on the emergency prepared- 
ness plan and the fact that the State has not yet submitted to you 
all of its revision. I wonder if you can tell us how long it would 
take FEMA to evaluate the plan after it's been submitted and how 
long it would take FEMA to ultimately advise the NRC of the ac- 
ceptability of a plan? 

Mr. Krimm. Once the plan is submitted, of course, it will be re- 
viewed by the Regional Assistance Committee, and depending on 
the time and the problems, they should be able do it in about 30 
days. 



545 

Mr. DoLAN. Three months. 

Mr. Krimm. Ninety days. 

The Chairman. Well, what assurance can you give us that Pil- 
grim won't start before that time? 

Mr. Krimm. That is not my decision. I can't give you any assur- 
ances. 

The Chairman. Whose decision is it? 

Mr. Krimm. That's the Nuclear Regulatory Commission's deci- 
sion. 

The Chairman. Can you give us any assurance about that? 

Mr. MuRLEY. I'll speak to that in my testimony, if I could. 

The Chairman. We'll hear from Dr. Murley, who is the Director 
of the Office of Nuclear Reactor Regulations at the Nuclear Regu- 
latory Commission. 

Mr. Murley. Thank you, Mr. Chairman. I'll summarize my re- 
marks, which I provided to the committee in more detail. 

First, I should say that we're not prepared at this time to recom- 
mended restart of the Pilgrim plant nor do we have a schedule for 
the restart for the plant. 

The Chairman. Let me ask just before you move on. You say, 
"we are not ready to recommend restart nor do we have a plan." 
Can you indicate to us what would be the factors that you would 
look for to determine whether you will have a plan or whether you 
will permit restart? What are the events? What are the things that 
have to happen? 

Mr. Murley. What I 

The Chairman. If you repeat them in your statement, I would 
like to permit you the full opportunity to do that but, as you move 
through the testimony, we're reaching the end of the hearing, so 
I'm going to maintain a little more flexibility. If you have it later 
on in your state